I’m an independent internal medicine physician with my own practice, Advanced Internal Medicine, in Paducah, Kentucky. My practice has served patients in Paducah for three and a half years. Paducah is a changing medical community. We have two competitive hospitals in our town that employ many of the specialists and physicians in our area. There’s still a good number of independent primary care doctors, like me, who run our own practices.

Three years ago, other independent doctors and I joined a local Accountable Care Organization (ACO). We were excited about the opportunity to come together to offer better care for our patients and leverage our size to compete with hospital employment. However, we didn’t see significant progress in our move to value-based care or a clear vision for how we would get there. At the end of our relationship with our prior ACO, after doing some research, we decided to partner with Aledade.

Working with Aledade has been a completely different experience.  From our first kick- off visits we could see that Aledade was different.  Aledade had a plan to address our local pain points and worked with us to get things right. Before Aledade, for example, our group of doctors didn’t have a plan for Annual Wellness Visits (AWVs) or HCC coding. We were all trying to tackle them separately without insight into an optimal workflow. With the Aledade App we have actionable data and can target our highest priority patients, to keep them healthy.

I have found that it is possible to participate in value based care and remain independent. I was the solo doctor figuring it out on my own, and it was time consuming and hard. When you partner with Aledade you don’t have to figure things out on your own. Having support in moving to the next level of value-based care has made all the difference. We now have someone from Aledade in our office every single week. They help us stay on track and keep in touch between visits. They’re there to help us break down barriers, so we can provide our patients the best care.

I’m looking forward to the next three years working with Aledade. The changes I’ve seen already in my practice are unparalleled.

This is National Healthcare Decisions Day Week (yes, that’s a little confusing). It is a week to consider the importance of end of life planning that is sponsored by The Conversation Project, an organization co-founded by a journalist who wrote:

“In my mom’s last years of life, she was no longer able to decide what she wanted for dinner, let alone what she wanted for medical treatment. So the decisions fell to me. Another bone marrow biopsy? A spinal tap? Pain treatment? Antibiotics? I was faced with cascading decisions for which I was wholly unprepared. After all the years I had written about these issues, I was still blindsided by the inevitable.

The last thing my mom would have wanted was to force me into such bewildering, painful uncertainty about her life and death. I realized only after her death how much easier it would have all been if I heard her voice in my ear as these decisions had to be made. If only we had talked about it. And so I never want to leave the people I love that uneasy and bewildered about my own wishes. It’s time for us to talk”

The Conversation Project was born from this experience, an organization created to help people talk about their wishes for end of life care. At Aledade, we share this vision. It is the right thing to do and aligns perfectly with the mission of Accountable Care Organizations that are trying to improve patients’ healthcare experiences while reducing non-beneficial health care costs. 80 percent of patients who die annually in the U.S. have Medicare as their primary insurance and approximately $170 billion is spent annually by Medicare on the last year of life; this equals 25 percent of all Medicare spending. Much of this spending is useful and important, but not all of it is, and Accountable Care Organizations are in a key position to try to improve end of life care in this country.

Some numbers:

  • 90 percent of people say that talking with their family about their end-of-life treatment preferences is important.
  • 27 percent have had this conversation
  • 23 percent have put their preferences in writing
  • 7 percent have had a similar conversation with their own doctor (the number is higher for Medicare patients: 27 percent)

On the other hand, 64 percent of physicians have completed their own advance directives and discussed it with a family member and 80 percent of physicians have a stated personal preference for comfort care over aggressive medical treatment at the end of life.

What do these statistics suggest? At least two things:

First, that we as physicians have seen what can happen when treatment preferences are not documented and shared with family: unwanted treatment that too often results in needless suffering for patients and their families. We have seen it, and we don’t want that experience for ourselves or our loved ones.

Second, that there are likely barriers that prevent physicians from offering this important aspect of care to all our own patients. Is it a conversation that takes too much time to fit cleanly into a provider’s schedule without spilling into other appointments and backing up a busy clinic? Is it the discomfort with broaching a potentially emotional and uncomfortable subject? The challenge of communicating around uncertain prognoses? Concern about applying our own choices and values to our patients’ most important decisions? Lack of clarity within the medical system around who “owns” end of life planning?

At Aledade, we are taking on the wonderful, difficult and important challenge to understand these barriers and address them. We help primary care practices identify patients who are most in need of end of life planning and offer medical providers training in using the Serious Illness Conversation Guide to discuss end of life preferences. We offer practices the option to partner with Iris Plans, a company with palliative care expertise that offers patients advance care planning via phone and video conference, so these conversations can be held at a time convenient for patients and in a way that allows family members who live far away to join and be included in the conversation in real time. We also have created a scorecard for hospices based on billing data and patient satisfaction surveys to help guide patients to the best possible end of life care.

For ourselves at Aledade we have encouraged our own team to use the Conversation Project Starter Kit to consider their own end of life preferences. This is not only because life usually does not go as planned for any of us, but also so that we can have direct experience with what it means to consider our own treatment preferences and what it is like to communicate our wishes to our families and our own medical providers.

As Robert Frost wrote, “The afternoon knows what the morning never suspected.” What we do know is that helping our patients live the best lives possible includes planning for what happens at the end of it.

If you drive by West Calcasieu Cameron Hospital (WCCH) in Sulphur, Louisiana, you’ll see eight healthcare offices. Inside are 13 physicians and their care teams, providing primary care, obstetrics, gynecology, and pediatric care to the families in Calcasieu and Cameron parishes, the hospital’s service area.
Some of the doctors have been in this community for over 60 years, establishing relationships as they care for generations of families. Throughout the decades, teamwork between the hospital, the primary care physicians (PCPs) who work for the hospital, and the surrounding independent primary care practices has been a constant. As Anne Billeaudeaux, WCCH’s Director of Business Relations and Physician Development, said, “the independence of the practices is just as important as our collaboration.”

At Aledade, our vision is a health care system based on value with independent, primary care practices at the center. WCCH proves that we’re not the only ones who share this guiding principle.

WCCH is working with the Aledade Louisiana ACO to improve the continuity of care, resulting in patients receiving a timelier follow-up and supporting care across the community. This effort started in March of last year, when WCCH’s IT department helped the hospital join an Admission Discharge Transfer (ADT) network. The ADT connects with the Aledade App, practices can find out in a timely way when their patients are in the ED and hospital. When patients are discharged, a case manager faxes practices if a patient isn’t discharged to their home.

Before, practices struggled to follow up if patients had been to the ED or hospital because notification was cumbersome and completely manual. When providers know about a hospitalization they are able to follow up in a timely way. A patient being discharged from the hospital with several new medications and changes in their daily care, can become overwhelmed navigating those changes alone. With the improved communication from the work between WCCH and Aledade PCPs can support their patients and help them better manage recovery.

WCCH wants to help prevent avoidable readmissions and keep patients healthier with the appropriate level of care. Because WCCH joined the ADT, many patients in Sulphur have visited their PCP after discharge and have been able to get the follow up care or education they need to stay healthy and out of the hospital.

Collaboration with the Aledade Louisiana ACO has been good for the hospital, the independent physicians, and most importantly, the patients. I asked a few of the key leaders from the hospital, as well as the independent primary care doctors, to talk about successes to date:

Kathy Doty, Director of Quality Assurance at WCCH

Our outcome-driven journey into quality started more than 10 years ago, with a CMS/JC project. We discussed sharing data with our partner physicians in a meaningful way on a regular basis. We learned how to use and apply this data, alongside our physicians. It led to a few uncomfortable talks, but we all knew this data could help drive improvements in care for our patients.
As care managers, we’re trained to avoid the rain clouds, which motivated us to embrace the shift to value-based care. We warned folks that if we missed the boat on value-based care not only would there be future financial penalties, we’d be left behind. We discussed both sides with our clinical team and chose to embrace the new system and implement at our own pace.

Janie Fruge’, Chief Executive Officer at WCCH

We always focused on meaningful ways to share our data and be confident in the data we receive. Through effective communication and actionable plans, we’ve improved care in our surgical initiatives, reduced central line infections, and decreased pneumonia diagnoses.
Our physicians and clinicians formed a virtual medical community home; the experience was mixed. Some primary care providers joined in, some didn’t commit right away. For the doctors who did participate, they found success and started speaking in favor of it. They encouraged the others to join, then Aledade helped everyone get on the same page. Now, the people who were the most skeptical are the biggest fans.
For us, and the physicians around WCCH, joining Aledade was a natural extension of our quality work. Our early efforts showed us how data could promote quality care. Aledade brought the tools, and helped us share ideas in a complete plan that we can all execute, together.

Dr. Maureen Lannan, Cypress Clinic

As we enter agreements aimed at lowering costs and improving care for a defined group of patients, the hospital/PCP relationship is critical, especially when it comes to the discharge process of patients.  Better communication between the hospital medical team, patients, caregivers, and the outpatient medical team is vital, so that patients do as well as possible after they return home.

In conclusion, value-based care is good for our patients, and Aledade has helped improve our systems. At the center is a durable partnership between the hospital and the independent primary care practices in the community. We look forward to seeing what the coming years bring, and continuing to turn our data insights into quality initiatives to better serve the community we’ve served together for over half a century.

I’ve been a family physician in Hoke County, North Carolina for many years. In this role, I walk with patients through all stages of life, from the birth of new babies to comforting patients and families in their loved one’s last days. I believe in the power of human connection: physical, emotional, and spiritual. It’s what my practice offers our patients.

Running an independent primary care practice today brings with it a range of financial and operational challenges. Accountable Care Organizations, often called “ACOs”, are in a unique position to reward providers for quality and better outcomes through preventive care, care coordination and avoiding unnecessary services. I believe that transitioning to value-based care will help my practice remain independent while I continue providing the high quality, personalized care my patients deserve.

I know my practice needs a partner to take our journey in value-based care to the next level. That’s why I’ve chosen to partner with Aledade to help us navigate toward better care at lower cost. Aledade offers us the technology, tools and support we need to succeed, allowing us- the physicians- to focus on quarterbacking our patients’ care.

More than ten years ago I was one of the first rural independent physicians to invest in patient portals, patient kiosks, and an EHR. I saw this as an investment in not only the way I practiced medicine, but also in my patients’ health. I feel the same way about the Aledade Technology Platform. It will provide real time alerts when a patient visits the hospital or emergency room, and tell us when patients visit a specialist or fill prescriptions. The platform creates lists of patients to reach out to for annual wellness visits, emergency room follow-ups and transitional care visits. It integrates data from various sources and provides unparalleled insight into my patient population to help me more effectively manage the quality and cost of their care.

In my rural community, I work with many patients who face tremendous health and socioeconomic challenges. While some may see a case of COPD or uncontrolled diabetes, we see an opportunity to have a conversation with our patients and discuss the larger picture of how we can help them. We are excited to use the Aledade tools to help us flag patients who need extra support so we can reach out and work to keep them out of the hospital.  This tool complements our existing work and supports customized care plans on which our whole team can collaborate.

I’m excited to partner with Aledade to launch an Aledade ACO in North Carolina in 2019. The future looks bright for patients and independent primary care physicians in Hoke County and throughout North Carolina, and I’m proud to be part of it.

A few weeks ago, we had a patient call around 9:00 am. She had been recently diagnosed with the flu, and was struggling to keep down any food or fluids. We were able to get her an appointment at the office within two hours of the call and administered IV fluids to prevent dehydration. If the patient hadn’t called us first, or if we didn’t have open-access scheduling, she would have likely ended up in the emergency department.

In the same week, another patient contacted us and said that she didn’t feel quite right. Again, we leveraged our open-access scheduling to get her into the office quickly. This patient was also scheduled for a knee replacement surgery within the next two weeks. She was concerned that her current condition would prevent her from proceeding with the surgery. I evaluated her and determined although she was without a fever, she had pyelonephritis, an infection of the kidney. At the visit, I gave her intramuscular antibiotics to treat the infection and contacted her orthopedic surgeon to provide a report on her visit and treatment plan.

Through the rest of the week, I saw her every day at the office to monitor her progress and keep her surgeon informed on her course of care. She was very anxious about the surgery but trusted that since I was monitoring her closely, I wasn’t going to let her go through it if I felt she wasn’t ready. Thankfully, she was able to make a full recovery in time to have the knee replacement. This could have resulted in significant perioperative complications had she not called us first.

At Dixie Primary Care, our patients know that we can be available if they reach out to us when they experience health concerns. If a patient can contact us before they go to the emergency department, there’s a good chance we can care for them at the office immediately, thereby saving them an unpleasant, lengthy, and expensive visit to the ER. Each of our providers keeps four acute appointments open every day which create 16 same-day consultation slots for the whole practice.

When I tell other doctors about our scheduling process, they often ask whether it is difficult to fill all of the same day appointments. Our response is that this is a conscious choice in an effort to serve our patients, regardless of whether we fill the slots. In some instances, we have used these appointments to reconcile medications after patients get discharged from the ER, hospital or rehabilitation facility. We have decided that it is more important to be available for our patients than to overbook our providers’ days.

This scheduling process parallels our mission to provide value-based care as it leads to remarkably low rates of ED utilization by our patients. Our rates are among the lowest in all of Aledade’s partner practices, which are already lower than many primary care practices across the country. It helps our patients get the right care, at the right time, for the right reason, thereby improving patient experience and compliance and decreasing costs.

A patient’s fears and concerns can be enough for them to turn to just anyone for help. For my family and friends, I would want them to see a doctor who knows them well and whom they can implicitly trust. This is what being a primary care provider is all about.

*This is the full 3,600 word CMS response letter. A summary of our thoughts is available on our blog.

November 20, 2017

Seema Verma, Administrator

Centers for Medicare & Medicaid Services

7500 Security Blvd

Baltimore, MD 21244

 

Re:       RFI: Innovation Center New Direction

Dear Administrator Verma:

Aledade (www.aledade.com) partners with 272 primary care physician practices, FQHCs and RHCs in value-based health care. Organized into twenty accountable care organizations across 18 states these primary care physicians are accountable for over 240,000 Medicare beneficiaries. More than half of our primary care providers are in practices with fewer than ten clinicians. We are committed to outcome-based approaches to determine the value of health care. We are committed to using technology, data, practice transformation expertise and most important the relationship between a person and their primary care physician to improve the value of health care.

Future of Medicare and Medicaid Innovation in Value-Based Health Care

We appreciate the opportunity to respond to the Center for Medicare and Medicaid Innovation’s request for information (RFI) on Sept 20, 2017. We seek to share what physician practices have learned in the transition to value and our views on how to continue moving forward.

Physician-only ACOs face unique challenges in model participation while also outperforming other types of ACOs[1][2][3]. We view the RFI through the lens of models that are led by physicians.

Guiding Principles

  • Choice and Competition in the Market –Congress has taken initial steps to reduce regulatory incentives encouraging the merger of hospitals and physician practices, but more needs to be done. New models should further eliminate payments for physician practices to merge with hospital systems such as facility fees creating higher payment for the same services and the 340B program making drug pricing uncompetitive in private practice.

 

Competition is also key to success in value-based health care. CMS should prohibit anticompetitive behaviors such as data blocking and anti-tiering provisions that prevent the creation of financial incentives for using high-value health care providers.

 

  • Provider Choice and Incentives – A model that provides a business case for improving care will attract voluntary enrollment by physician practices. These models should, over time, put physician practices at financial risk, but that risk must be proportional to the finances of independent physician practice and not so large as to favor consolidation of practices. Models should move over time to a financial and evaluation structure focused on analysis of their local market. Physician practices should be able to accelerate the move to a difference-in-difference approach by taking on risk.

 

  • Patient-Centered Care – A strong primary care physician-patient relationship is the strongest tool available to create more value in health care. This proposition is strongly supported in the health services research literature and in the results of the MSSP.

 

  • Benefit Design and Price Transparency – Price transparency to model participants and to the consumer of health care creates competition by informing the choices of both beneficiaries and referring physicians. Benefit design should incentivize the building of the primary care physician-patient relationship and other cost-saving choices.

 

  • Transparent Model Design and Evaluation – Transparent design serves as a key component of voluntary provider choice. Uncertainty creates reluctance, but transparency promotes understanding and increases commitment. For evaluation, we favor difference in difference models of evaluation.

 

  • Small Scale Testing – All models should be designed with success and scalability in mind. We believe that Accountable Care Organizations can serve as unique test beds for innovation models due to ACO incentive to reduce total cost of care.

 

Focus Areas

  • Increased participation in AAPM – Three primary levers for physician practices:
    • Refine existing benchmarking methodology to better relate to local markets and reflect the health of the underlying population with accurate risk scoring
    • Calibrate risk to the finances of physician practices while still offering within-model reward for taking on risk for most models including all MSSP tracks
    • Create a new, more flexible, and sustainable version of Next Generation ACO for full risk taking with traditional Medicare
  • Consumer-Directed Care & Market Based Innovation Models – Allow Medicare beneficiaries to identify to CMS their primary care physician and create models that allow for beneficiaries to share in savings if their PCP participates in a savings model
  • Medicare Advantage Innovation Model – Facilitate innovative MA plans by allowing new physician-run plans to use existing Medicare infrastructure (e.g., MAC claims processing systems) so physicians can focus on population health management.
  • Physician Specialty Models – Focus on models that work within the framework of a total cost of care model as well as stand-alone models.
  • Prescription Drug Models – Test inclusion of Part D drugs in total cost of care models.
  • State-Based and Local Innovation – In addition to focusing on new models, CMMI can serve as a resource for physicians to learn about state and local innovation.
  • Mental and Behavioral Health Models – Use total cost of care models to test greater investment in mental and behavioral health.
  • Program Integrity – Allow physician practices, ACOs and other model participants to collaborate with CMS on surveillance and increasing transparency.

Increasing Participation in AAPM

Advanced Alternative Payment Models should be judged based on their ability to attract participants. The primary outcome measure for an AAPM should be how much value it created. The value is a combination of the percentage of savings or other outcome improvement measure times the number of people the model effected. There is no better way to encourage participation than a well-designed and well-understood model. This model relies on provider choice and transparency in development and is designed to attract willing physicians and other participants.

For physicians the crux of an advanced versus regular APM revolves around the phrase “more than nominal financial risk.” One of the first questions we get from our physicians is will the ACO qualify as an AAPM? Whether that risk is something that a given physician should undertakes revolves around how well the model benchmark separates risk due to the effective delivery of health care services and population health services versus risk that is due to uncontrollable circumstances or insurance risk. Aledade now partners with over 1000 primary care physicians who believe in population health and their role in it. However, they do not feel responsibility for events they can neither control nor influence. We have seen physicians and their staffs make great efforts to get the most non-compliant person into the office and out of the emergency department, on their medications and working towards their own health. However, no primary care efforts will influence whether that person develops unavoidable cancer. Nor will any primary care initiative account for regional differences in cost structures that have developed over decades. If you are financially responsible for whether a patient develops an unavoidable cancer you are an insurance company and that is a business that most physicians do not want to be in. All models should use risk scoring methodologies that accurately set targets, particularly advanced alternative payment models where the participant is taking risk. Models should acknowledge that changes in health will vary between model participants. This means that for a given model participant risk adjustment should be able to raise or lower the cost target. At the same time, we recognize that CMS has a vested interest in not rewarding model participants for changing their risk score more than the underlying health of the beneficiary population changes. At the program level this could take the form of either a cap in year over year change or a program wide adjustment factor. Regardless of the method CMS chooses to protect the program, an individual model participant’s cost target should track changes in their risk score (i.e. if the population is sicker the target higher, if the population is healthier the target lower) even if the magnitudes of the change are not 1:1 in order to protect the program at large.

The other way to increase the accuracy of model benchmarks is to relate them to local health care markets. Finally, since insurance risk cannot be completely eliminated the risk to which physician practices are exposed to must be more than nominal, but never ruinous. The goal of downside risk is to motivate the model participants and give the payer assurance that the ACO’s interests are aligned with the payers or in the case of Medicare society’s interests. Rather than setting downside risk in its current mostly symmetrical fashion just because it feels fair, CMS and other payers should set downside risk to accomplish the goal of motivation. Models like Track 1+, that relate risk to the finances of the participants instead of the model benchmarks will greatly encourage AAPM participation, particularly if those models offer rewards in the model for taking on risk, which is not currently the case with Track 1+.

Finally, we recommend that CMS dramatically reduce the timeline for when a physician is rewarded with the 5% bonus created by MACRA. Under the current timeline, a physician who makes a decision to join an AAPM in July of 2018 (most AAPMs have July deadlines) for 2019 participation will not see their 5% bonus until May 2021, nearly three years later. The physician could receive payments or pay losses based on their performance in the AAPM in September 2020 or nine months earlier than the bonus they get just for participation. This timeline is serving as a drag on AAPM participation. For AAPMs that require full year participation CMS could assume participation for 2019 as early as the finalization of the model participant list in December 2018 and then retroactively look at 2018 claims to determine whether the physician is a qualifying professional. This would allow CMS to move the MACRA AAPM bonus payment forward two years to spring 2019 and serve as a much better incentive for physicians to join an AAPM this summer. Principally, CMS should always be looking for ways to shorten the time frame from when physicians take action to when the outcomes of those actions are rewarded.

In conclusion, to encourage greater AAPM participation for 2019 we recommend:

  • Design new models and refine all existing models to focus on value creation that is within control of physicians and patients through local market benchmarking and accurate risk scoring as no incentive payment will ever overcome significant transfer of insurance risk from payer to provider
  • Require risk, but make the risk motivational and rewarding, not ruinous
  • Dramatically shorten the MACRA AAPM bonus timeline and continually seek to shorten the timeline between action and outcome
  • Create a new, more flexible, and sustainable version of Next Generation ACO for full risk taking with traditional Medicare

Consumer-Directed Care & Market Based Innovation Models

We believe one of the strongest tools to create value in health care is the relationship between primary care physician and patient. We suggest centering consumer-directed care around that relationship. CMS should create a mechanism for beneficiaries to select their primary care physician and encourage, but not require, them to do so. If a beneficiary selects a PCP who is an alternative payment model and that PCP succeeds in the model, the beneficiary should share in that success.

We suggest that this be in the form of reduced deductible and/or Part B premiums in the next year. We believe that by the patient should get the benefit automatically and that the ensuing discussion between patient and PCP on the success of the model will align incentives and create loss aversion on behalf of both parties that will benefit all involved. We are missing out on an opportunity when we only align incentives between health care providers and health care insurers. By creating an opportunity for Medicare beneficiaries to realize savings as well, we engage all parties in the effort.

In addition and not necessarily in conjunction, we recommend that CMS streamline the waiver process and expand it to allow model participants to offer reduced cost sharing to Medicare beneficiaries and to allow model participants to invest not just in health care related services such as home monitoring equipment, but also social services such as accessibility to the home and nutritional needs.

Medicare Advantage Innovation Model

Medicare Advantage is an excellent opportunity to align incentives, but it suffers from a lack of competition[4]. Since 1997, Medicare Advantage has tested the premise that the private sector can compete with Medicare in providing health care to seniors. Through its many iterations and refinements, two aspects of the program have never changed: First, to compete with Medicare, private companies must take over claims processing from the Medicare administrative contractors (MACs). Second, those companies must also create their own provider contracts. Twenty years since the program began, health care plan competition consists of much more than efficient claims processing and provider contract negotiations. Yet these capabilities are still two of the main barriers to entry into Medicare Advantage, blocking efficient and innovative providers from participating in the program. We propose removing these barriers by opening up Medicare Advantage to health care providers without a dependency on legacy plan capabilities such as claims processing and network contracting. We believe that the two greatest drivers of health care value are increasing and maintaining competition and aligning incentives of physicians and other health care providers with Medicare and with Medicare beneficiaries. Our proposal will do both by building a network on top of Medicare participation—not instead of it—and leaving claims processing in the highly experienced, efficient hands of the MACs. Making this change will shift the conversation about provider networks from price concessions and market power to creation of truly patient-centric, quality-based networks led by primary care. This will result in better care for patients, while allowing traditional Medicare to realize deeper savings through competition and aligned incentives. By removing traditional plan operations as a barrier to entry for Medicare Advantage, Medicare can create a path for successful provider groups to move into Medicare Advantage. This increase in competition will benefit both Medicare beneficiaries and health care providers. We discuss this proposal in greater details in Health Affairs[5]

CMS should also review current Medicare Advantage regulations to ensure they encourage participation in value based contracting. For example, the Performance Based Incentive Payment regulations have not been updated since the emergence of accountable care and other models.

Physician Specialty Models

CMS should explore models for specialists that integrate with total cost of care models and models that stand alone. As CMS works on physician specialty models, we recommend that it always consider the effects on other models. We further recommend that in cases where models do overlap that the model with the most risk would receive precedence in assign the financial outcomes of the model. In all cases, overlap should never result in a situation where costs are assigned to one model due to another model that are higher than historical costs for the model participant. For example, if a joint replacement model overlaps with a total cost of care model the joint replacement could be assigned the price of $20,000. So the total cost of care model gets assigned $20,000 no matter what the actual cost is. However, if the participants of the total cost of care model historically have an average cost of just $18,000 for a joint replacement, then the overlap is creating an artificial $2,000 loss. This situation must be avoided as it creates animosity rather than collaboration.

Mental and Behavioral Health Models

Total cost of care models are unique opportunities to test further investment in mental and behavioral health. When health care providers are responsible for total cost of care it removes incentives to cost shift and creates an incentive to maximize the volume derived from additional investment in mental and behavioral health.

Our experience with the Comprehensive Primary Care Plus (CPC+) program, specifically its Track 2, shows the difficulty in enabling behavioral health care in the primary care setting. Primary care physicians view this work as distinct and specialized requiring dedicated staff and specific expertise. To fund these activities, behavioral health is not served well by wrapping its funding into other funding streams. It is better for it to be clear to physicians what resources are dedicated to behavioral health. We recommend that CMS clarify CPC+ Track 2 behavioral requirements and consider a new model for behavioral health within total cost of care models.

For CPC+ Track 2, we recommend CMS issue a white paper or other education that ties a specific amount of the increase between CPC+ Track 1 and Track 2 to the behavioral health integration requirements. This would give practices much needed information to inform investment levels in behavioral health. This need not be a requirement, but simply filling an existing knowledge gap that we believe is holding back investment and participation in behavioral health integration with primary care.

For a new model of behavioral health, we recommend that CMS launch a behavioral health model that will provide new payment models within total cost of care organizations like ACOs and their participants. Structured around a predictable payment schedule, this investment can test behavioral health specific resources within the context of an organization that is responsible for the total cost of care. CMS could also test the effects of varying payment levels of existing behavioral health payments within a total cost of care organization. By allowing the organization to decide on how best to deploy the resources, either at the practice level or the organizational level, CMS creates flexibility for organizations of different make-ups to apply behavioral health integration as it best relates to their local health care market.

Increasing Value in Health Care through Innovation

We believe there are three main drivers of increased value in health care: competition, aligned incentives and professionalism. Competition increases value; however, it must be encouraged and even protected. Unlike professionalism and aligned incentives, competition does put downward pressure on health care provider’s margins creating an incentive for health care providers to find ways to reduce competition. CMS must always be aware of the effects that new models will have on competition. These effects are not always intuitive. It is possible for a model to both encourage further consolidation among large health care providers and also provide an avenue for independence for smaller health care providers. For example, the accountable care model is an opportunity for independent practices to take advantage of today’s advances in technology and data to help their patients navigate the whole health care system without needing to vertically integrate. It can also be a catalyst for a large integrated delivery system to complete their vertical integration efforts. To understand these sometimes competing effects, markets must be critically evaluated for competition and the make-up of model participants should be understood and categorized by type of provider physician practices, hospitals, other facilities, and integrated delivery networks. This does not always present itself as classical consolidation. For example, non-compete clauses in hospital employment contracts (eg that bar medical practice within 50 miles for 5 years) could be an anti-competitive abuse of market power that would not show itself in a traditional market analysis. Finally, models must also consider that health care providers do not just compete among each other they also compete with insurance companies for share of health care dollars. Models should consider the effects on competition with health insurers as well as competition among health care providers.

Aligned incentives is the most recent addition to value driven health care. It is a challenging task. In health care rarely is the need for a service known in advance by the consumer of that service. To address this and other uncertainties, consumers transfer risk to health insurers thereby created a three party transaction between the health care provider, the health insurer and the consumer of health care services. Further complication exists in the third-party administrator situation where the health insurer (the party that bears the uncertainty) and the party that contracts with health care providers are different. Finally, the quality of the health care service provided is hard to measure and the definition quality itself is subjective. These complications can create disparate incentives where a physician may be incentivized to perform more tests, while a health insurer wants fewer tests, a third party administrator gets a percentage of the tests and the patient has no idea how many tests they really need. Our challenge is to align incentives in such a way to maximize the value of a dollar spent on health care. In order to do so we should create models that reward health care providers for increasing the value of the health care dollar and ensure that health care consumers also receive that value through lower premiums over time or even through direct payments to consumers.

Medicine has always been blessed with a high level of professionalism. That professionalism must be respected as we seek to increase value through competition and aligned incentives less we lose the value it brings to health care. Physicians, and indeed most health care professionals, feel their autonomy is under threat from nearly all quarters. Poorly designed quality measures that either do not help a physician provide better quality or impose unjustified burdens for data collection distract from the physician/patient relationship. Pressure on the margins for physician services combined with ever-increasing administrative burden to document physician services assault private practice from both the revenue and cost side decreasing competition as physicians seek negotiating power to increase revenue and scale to spread out the administrative burden. As we align incentives and increase competition, we should do everything we can to ensure we do not lose value that is created by professionalism.

Conclusion

We appreciate the opportunity to comment on the future direction of CMMI. We believe there is incredible opportunity for CMS to continue to lead the movement towards value based payment in health care.

As CMS conceives of and evaluates new models we summarize our thoughts as:

  • Models should be attractive enough to independent physicians that they choose to participate and to take risk
  • Competition creates value as well and CMMI should consider the competitive effects of all models
  • Professionalism of health care providers creates value as well and should be preserved and respected

We look forward to continuing to work with CMS to increase the value of the health care dollar. Please contact me or Travis Broome (travis@aledade.com) if you have any questions about our submission and/or we can be helpful to you and your staff as you explore new directions for CMMI.

 

[1] http://www.nejm.org/doi/full/10.1056/NEJMsa1600142#t=article

[2] http://www.nejm.org/doi/full/10.1056/NEJMp1709197?query=TOC

[3] http://www.ajmc.com/contributor/travis-broome/2017/10/cms-releases-medicare-shared-savings-program-2016-results

[4] http://www.commonwealthfund.org/~/media/files/publications/issue-brief/2015/aug/1832_biles_competition_medicare_private_plans_ib_v2.pdf

[5] http://www.healthaffairs.org/do/10.1377/hblog20170706.060925/full/

As the new administration continues to chart their course in value-based health care they have formally asked for the public’s input. We shared with CMS what we and our partner physician practices have learned in the transition to value and our views on how to continue moving forward. Below is a summary of our full letter which can be found here.

We believe there are three main drivers to increase value in health care:

  • Competition
  • Aligned incentives
  • Professionalism

First, competition increases value; however, it must be encouraged and even protected. Unlike professionalism and aligned incentives, competition puts downward pressure on health care provider’s margins. This creates an incentive for health care providers to find ways to reduce competition. Due to this, CMS should evaluate the competitive effects of new models. Second, aligning incentives creates the greatest opportunity for value creation; however, it is a challenging task and our primary subject today. Third, medicine has always been blessed with a high level of professionalism. As we align incentives and increase competition, we should do everything we can to ensure we do not lose value that is created by professionalism.

Choice and Competition in the Market and in Models

Congress has taken initial steps to reduce regulatory incentives encouraging the merger of hospitals and physician practices, but more needs to be done.  New models should further eliminate payments for physician practices to merge with hospital systems such as facility fees creating higher payment for the same services and the 340B program making drug pricing uncompetitive in private practice.

Competition is also key to success in value-based health care. The administration should prohibit anticompetitive behaviors such as data blocking non-compete clauses in physician contracts and anti-tiering provisions that prevent the creation of financial incentives for using high-value health care providers.

Provider Choice and Incentives – Increasing AAPM Participation

A model that provides a business case for improving care will attract voluntary enrollment by physician practices.  Principally, these models should, over time, put physician practices at financial risk that is proportional to the finances of independent physician practice and not so large as to favor consolidation of practices. Models should move over time to a financial and evaluation structure focused on analysis of their local market. Physician practices should be able to accelerate the move to a difference-in-difference approach by taking on risk. These principles will increase advanced alternative payment model (AAPM) participation.

For physicians the decision of whether to participate in an advanced versus a regular APM revolves around the phrase “more than nominal financial risk.” One of the first questions we get from our physicians is will the ACO qualify as an AAPM? Whether the answer should be “yes” is decided by how well the model benchmark separates risk due to the effective delivery of health care services and population health services versus risk that is due to uncontrollable circumstances or insurance risk. Aledade now partners with over 1000 primary care physicians who believe in population health and their role in it. However, they do not feel responsibility for events they can neither control nor influence. We have seen physicians and their staffs make great efforts to get someone into the office and out of the emergency department, on their medications and working towards their own health. However, no primary care efforts will influence whether that person develops unavoidable cancer. Nor will any primary care initiative account for regional differences in cost structures that have developed over decades. All models should use risk scoring methodologies that accurately set targets, particularly advanced alternative payment models where the participant is taking risk. Models should acknowledge that changes in health will vary between model participants. This means that for a given model participant risk adjustment should be able to raise or lower the cost target

The other way to increase the accuracy of model benchmarks is to relate them to local health care markets. Comparing the ACO or other model participant to other health care providers around them not to themselves. Finally, since insurance risk cannot be completely eliminated the risk to which physician practices are exposed to must be more than nominal, but never ruinous. The goal of downside risk is to motivate the model participants and give the payer assurance that the ACO’s interests are aligned with the payers or in the case of Medicare society’s interests. Models like Track 1+, that relate risk to the finances of the participants instead of the model benchmarks will greatly encourage AAPM participation, particularly if those models offer rewards in the model for taking on risk, which is not currently the case with Track 1+.

Completing the Glide path in Value Drive Health Care

Medicare Advantage is an excellent opportunity to align incentives, but it suffers from a lack of competition. We believe there is an opportunity to create health care value through a new model of Medicare Advantage. Our proposal will allow physicians to build a network on top of Medicare participation—not instead of it—and leaving claims processing in the highly experienced, efficient hands of the MACs. Making this change will shift the conversation about provider networks from price concessions and market power to creation of truly patient-centric, quality-based networks led by primary care. This will result in better care for patients, while allowing traditional Medicare to realize deeper savings through competition and aligned incentives. By removing traditional plan operations as a barrier to entry for Medicare Advantage, Medicare can create a path for successful provider groups to move into Medicare Advantage. This increase in competition will benefit both Medicare beneficiaries and health care providers. We discuss this proposal in greater detail in Health Affairs.

We appreciate the opportunity to engage with CMS on the future direction of value based health care. We believe there is incredible opportunity for CMS to continue to lead the movement towards value based payment in health care.

To succeed in value-based care, practices need to help patients get the right care at the right time in the right setting. At Aledade, we help practices do just that by reducing unnecessary emergency department (ED) use, improving care coordination with specialists, and managing chronic conditions.

Another way we improve quality is by engaging home health providers as key partners. Home health care accounts for eight to ten percent of total spending across our ACOs.

A primary care physician (PCP) can order home health for a patient in a hospital or another setting. Every 60 days after that, the physician needs to recertify the services as medically necessary for the patient. In the past, PCPs had limited insight into home health quality. They might not know when patients started home health care. They might not have clear communication during the recertification (or recert) process. This often leads to significant care gaps, and risks for the patient.

Our partner practices in Arkansas grew frustrated with the recert process, so they decided to revamp it. When a home health agency submits a recert request to the PCP, the practice’s care manager reviews it right away. The care manager checks if the patient is improving, and calls the home health agency to learn more. The office then schedules the patient for an appointment to review their progress towards their health care goals. Together, the PCP and the patient decide if the patient should continue with home health care. Sometimes another service, like Chronic Care Management, social support, transportation, or education, is more appropriate.

One patient in the Arkansas ACO had received home health services for diabetes management for more than a year. Both the patient and the PCP were frustrated. The patient’s A1C hadn’t improved and their ED utilization had increased. The practice stopped home health, and enrolled the patient in an in-office diabetic education program. There, the patient learned about triggers and how to manage insulin levels. The patient was also able to meet with the practice’s nutritionist for help with planning groceries and meals.

According to the team at Dr. Walker’s Clinic in De Queen, Arkansas, the new home health workflow ensures the practice reviews “all patients prior to admission to home health and performed at every recertification. We have a nurse that manages this population and meets with our home health agencies bi-weekly to discuss goals, recerts, and discharges.”

In West Virginia, our partner practices worked with home health agencies to reduce preventable admissions and readmissions. The home health agencies created a Collaborative Performance Review. They identify the hospital utilization of home health patients and find out how many hospital admissions were readmissions. They also look at patients who screened positive for depression, falls risk, and ED overutilization. This summary finds gaps in patient care, showing how the practice could have prevented a patient’s admission or readmission.

According to Dr. Tom Bowden of Charleston Internal Medicine in the Aledade West Virginia ACO:

“The transition from hospital to home is a critical step in the well-being of our patients. Partnering with home health agencies that can assist us in this process is vital. Finding the home health agencies that are willing to work with us, make changes, provide the care our patients need and track quality metrics will certainly help reach the triple aim of improving health outcomes, improving the patient experience and lowering health care costs.”

All of this starts with a question: “What information from would be most helpful when making a recert determination?”

By focusing on this question, we’ve developed a form for home health agencies. We found home health agencies were eager to provide the necessary information, as were the PCPs. This summary, and the conversations that came with it, are still in the early stages. However, we expect that more communication will identify the most necessary recerts.

Better home health care means patients get the right, high quality care. We work with our home health partners to transition patients from skilled nursing facilities, nursing homes, and hospitals safely and sooner when possible. Home health also helps to proactively keep high risk patients safely out of the hospital. This requires close partnerships with home health agencies, and the communication to paint a full picture of the patient’s health. Armed with this, Aledade’s partner practices can ensure their patients get coordinated care in the right place at the right time.

The 2016 results are in and Aledade Accountable Care Organization (ACO) practices saved Medicare more than $9.3 million! The Aledade West Virginia ACO not only reduced costs 5% below the Medicare benchmark, but also received a shared savings check. In 2015, we brought together a unique group of 11 independent primary care practices that understood the importance of collaborating on improving health. Together, our partner practices have created a strong network that have reduced unnecessary hospital visits and kept patients safely at home, managed high-risk patients through a robust care management program, and provided better coordination of patient care with specialists and other providers in the medical neighborhood. We are very proud of our partner practices’ incredible progress and dedication in these key initiatives that have helped improve patient outcomes. “Teamwork and quality are always a winning combination. None of us are as smart as all of us together, and that is why we joined the ACO, said Dr. Jonathan Lilly, a Vice Chair of the West Virginia ACO. “We’re so proud of the ACO’s work in improving care and reducing costs in West Virginia.”

At Aledade, we know the value data offers to primary care physicians (PCPs) in helping them to deliver high-quality, coordinated care. We believed that if doctors receive practice workflow support, technology, and analytics, they are in a better position to deliver the highest-quality care while reducing unnecessary costs. In West Virginia, our physicians get a real time report when their patients show up at the hospital. With this knowledge they have been able to coordinate with hospital providers and support patients coming out of post-acute setting, reducing hospital readmissions, unnecessary days spent in ERs and the number of days patients spend in skilled nursing facilities. Dr. Ghali Bacha, an ACO member, said, “By joining the ACO and utilizing Aledade’s technology and support, our practice has significantly reduced our patients’ unnecessary emergency department visits and hospitalizations in 2016. Helping our patients get the right care in the right place at the right time has been a major accomplishment.”

Aledade equips PCPs with direct practice support and tools to utilize data to deliver high-quality, coordinated care. Taking data from multiple sources helps doctors keep patients healthier and out of the ER, makes it easier to prioritize their time and their practice’s time for patients who benefit the most from programs like Transitional Care Management (TCM), Chronic Care Management (CCM), and Annual Wellness Visits (AWVs). By implementing care management programs in our practices, both providers and patients have seen significant benefit. In a recent blog, ACO partner physician, Dr. Beckett talked about how improving patient information and care coordination with the local hospitals has made a real difference. He shared a success story about “the patient who previously went to the ED up to twice a week has now gone six weeks without returning.” While this is only one exceptional example of success, this is fortunately a trend we are seeing across all our West Virginia practices and plan to continue to share future success stories.

As Aledade West Virginia ACO’s Medical Director, Dr. Tom Bowden put it, joining the ACO “helped better foster our relationships with patients and other health care providers and helped form that bridge to other doctors and hospitals.” And we have done just that. Practices have worked with local specialists in improving communication to make the patient experience as seamless as possible. Kanawha County specialists have worked closely with our PCPs on referral management to better coordinate and manage patient care. Whether, it’s meeting in person to strategize referral processes or getting systems aligned virtually to get real time data on their patients, the dedication to improving care coordination has driven unnecessary spending down and quality of care up.

In our first performance year, we have established a strong network of providers who have been able to remain independent by driving down costs all the while improving quality of care for their patients. The ACO strives to get every person the right care at the right time in the right place. The proof is in the numbers. 368 fewer West Virginians needed to be admitted to the hospital, 136 of those were readmissions that were prevented by reducing complications. Over 400 West Virginians ended up in their physician office instead of the emergency room. They spent 566 more days at home instead of in a skilled nursing facility and saw their primary care physician 10% more often to help make all this happen. In 2016, the ACO achieved a total savings of $3,197,252, with shared savings of $1,566,654. With continued dedication and hard work on ACO initiatives, we are moving in the right direction for bigger and better things this year and the coming year. We are excited for the future of our ACO in helping create a better health care system and better care for West Virginians.

We started Aledade with the goal of building a new model of primary care – one that’s good for patients, good for doctors and good for our society. In just three years, we have brought this new model to more than 200 practices across 17 states – practices who collectively care for more than a million patients. We have brought it to the Medicare Shared Savings Program (MSSP) as well as other payers including Medicaid, Medicare Advantage and commercial health plans.

Our model isn’t easy. It combines both on-the-ground support and a cutting-edge technology platform – one that works with over 60 electronic health records. But it also requires sweat equity – investments of valuable time and effort by our dedicated partner practices and Aledade staff. So, it’s important that we take a close look at how we define success. To us, it’s always been a clear but challenging metric: is what we are doing good for patients, good for doctors, and good for the health system?

For patients, Aledade emphasizes more personal, preventive, and coordinated care – the quality of care that you’d want for your own mother or father. In 2016, both of our ACOs from 2015 improved their quality measures for things like controlling blood pressure and ensuring vaccinations and screenings. Our ACOs, overall, are improving their quality scores, and their patients are taking note. In a recent Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey, Aledade physicians were rated by their patients at an average of 9.3 on a scale of 0 to 10 – above the average for the over 400 MSSP ACOs.

Our practices are doing the right things. They are delivering many more preventive and primary visits, they are reaching out to patients to help them with transitions from hospital to home, they are, for the first time, hiring care coordinators who help those who need extra help. And it works. In every Aledade ACO– not just those that earned shared savings—avoidable emergency room visits dropped, readmissions plummeted, preventable hospitalizations from congestive heart failure, pneumonia, and pulmonary disease fell. Collectively, our ACOs prevented more than 1,500 hospitalizations. Aledade ACO practices are giving their patients better care – and we hear it in their stories, and we see it in the data.

Second, we want to make sure that what we’re doing is good for health care providers. Being part of an ACO has to be valuable, and sustainable, for our partner practices. In a time of increasing consolidation and a health care market that often doesn’t foster real competition, our goal is to help independent primary care practices thrive, and our partner practices succeed in value-based care.

Aledade ACO practices provide more – and more intense – primary care. By conducting more annual wellness visits, helping patients through transitions of care, and implementing chronic care management programs, our practices are seeing a return for their work. By implementing value-based care and practices transformation initiatives, our ACOs redirected health care dollars toward primary care and away from hospitals and emergency care. That is, our practices delivered better care and kept people healthier. The health of their practices did not suffer; in fact, they thrived.

And it’s important to note that they saw these returns in health and the bottom line while also lowering costs for society as a whole. That’s our third target for success.

During the 2016 performance period , Aledade’s ACOs – comprising 142 practices with over 80,000 patients in 11 states (Arkansas, Delaware, Florida, Kansas, Louisiana, Maryland, Mississippi, New York, Tennessee, Virginia and West Virginia) – saved Medicare more than $9.3 million. Five of our seven ACOs came in under the benchmark set by Medicare, and one was right at benchmark. Two of these – in West Virginia and Florida – exceeded the savings threshold so that Medicare will be sending them a shared savings check. We couldn’t be happier for those practices and the teams that support them, and we’re proud to be their partners.

Proud, but not satisfied.

If not for historically-low rates of inflation nationwide and the idiosyncratic way Medicare measures savings, many more of our ACOs would have earned savings. In Delaware, for example, we reduced costs by a whopping 3.3 percent over last year, and we’re on track to do even better in 2017. In fact, research shows that the savings from ACOs are generally undervalued. ACOs should be rewarded based on whether they improved care and lowered costs more than their local competitors – not a nationwide average. We’ve already proposed some improvements to the way that ACOs are measured.

Medicare also offers a regional inflation update to ACOs in their second three-year contract, which means young ACOs face uncertain market dynamics, but ACOs like many of ours, approaching that second contract, will have more accurate benchmarks. The combination of regional inflation for historical costs and regional benchmarking for this year’s costs reward ACOs that have bent the cost curve persistently in their regions, and have the patience and resources to plan for the long term.

The simple answer is that transforming health care just isn’t a simple thing. It takes a lot of work, a lot of creativity, some patience, and some time. But it works. Studies show that the proportion of ACOs that earn savings nearly doubles from year one to year four. We already have data that our ACOs are performing well in their regions. And with our new partnerships with commercial payers and Medicare Advantage, we’re finding new ways to promote value-based care for independent, primary care practices.

We’re on the right track. Our partner practices are taking the right steps. And the data for 2016 proves it. Despite all you hear about our broken health care system, Aledade practices and our staff are working day in and day out to transform health care in our country so that it delivers better care and lowers costs. That’s why Aledade exists. It’s why we’re so committed to our work. And I’m thrilled to see it’s bearing fruit.