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Value-Based Payment Lessons from a Michigan FQHC Kathleen J. Dunckel, MD Alcona Citizens for Health, Inc. [email protected]

Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

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Page 1: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Value-Based Payment Lessons from a Michigan FQHC

Kathleen J. Dunckel, MD

Alcona Citizens for Health, Inc.

[email protected]

Page 2: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Keep the Triple Aim in mind…

Improved health – clinical quality measures, which ones?

Enhanced patient experience – patient satisfaction surveys

Lower cost - compared to what?

benchmarks, risk scoring

total expenditures

ED, inpatient, post-acute care utilization

Of your population – attribution, assignment

Page 3: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Alcona Citizens for Health, Inc.

dba Alcona Health Centers

7 counties in northern lower Michigan and the UP

Alpena, Alcona, Iosco, Emmet, Cheboygan, Chippewa and

Mackinac

13 medical clinics, 2 dental clinics, 1 MDCH school-based

clinic, 13 Behavioral Health school clinics, 2 pharmacies

30,000+ patients

7,000+ Medicare beneficiaries

Page 4: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Our Story Begins…

Experience with chronic disease management for 17+ years

Health Disparities Collaboratives in the early 2000’s

Michigan Primary Care Transformation (MiPCT) Demonstration

Project 2011-2016

Bureau of Primary Health Care requirements for FQHCs

Electronic charting and practice management since 2008

Extensive internal IT network

All sites PCMH designated

Experience with Integrated care initiatives, e.g. Behavioral Health

& Primary Care

Page 5: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Challenges

2012 – tried to form an MSSP ACO with local Michigan providers

Minimal interest from potential partners

Other FQHC’s – mostly Medicaid patients

Non-affiliated hospitals – no incentives

Lack of data sharing with CMS

Lack of understanding of patient barriers

1/3 on disability

Limited community resources, e.g. transportation

Page 6: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

#1 Challenge

Unable to achieve minimum attribution numbers

In 2016:

total Medicare 7069, Medicare FFS 5601, attributed 2168

To play the game, we needed to better understand the rules!

Page 7: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

From the CMS rule book:

Assigning beneficiaries – Track 1 & 2 ACO’s

Final retrospective assignment at the end of the year, using the

most recent claims, i.e. the past 3 months

Preliminary prospective assignment quarterly; lists are

provided to each ACO

A beneficiary assigned this year may not have been assigned in

a preceding year, and may not be assigned next year

Page 8: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Assignment Criteria

A. Record of Medicare enrollment

B. At least 1 month of enrollment in Part A & B, and no

months of Part A only or Part B only

C. No months of Medicare Advantage or PACE*, i.e. only

traditional Medicare Fee-for-Service

D. Not assigned to another Medicare shared savings

initiative

E. U.S. resident

*Programs of All-Inclusive Care for the Elderly

Page 9: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Assignment Criteria (continued)

F. Received at least 1 primary care service from a physician

utilized in assignment* within the ACO

*Primary care physicians utilized in assignment: internal

medicine, general practice, family medicine, geriatric medicine,

pediatrics

FQHC’s/RHC’s – only beneficiaries who had at least 1 primary

care service from a physician NPI (MD/DO) are eligible for

assignment

Page 10: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Assignment Policy Steps

If screening criteria A through F are met,

a beneficiary is eligible to be assigned to an ACO

Step 1:

At least 1 primary care service furnished by a primary care

practitioner, or ACO professional at FQHC’s/RHC’s

AND, the plurality of the primary care services were

furnished by the ACO

i.e. more allowed charges by all ACO participants than by

other ACO’s or non-ACO providers of the same type

Page 11: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Impact on AHC’s attribution

High mid-level provider to physician ratio, i.e. no physician visit

Patients receiving care elsewhere

Snowbirds

Referral patterns to tertiary centers, e.g. the old Burns Clinic

Turnover of attribution

No physician visit – 1st reason

Plurality of care elsewhere – 2nd reason

Medicare Advantage enrollment – distant 3rd

Page 12: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Back to Our Story…

Joined National Rural Accountable Care Organization (NRACO), now

Caravan Health, in 2014

Reorganized in 2016 with ACO Investment Model funding, now in one

of 2 Michigan ACO’s

8-9 partners, mostly small rural hospital systems, to achieve

attribution numbers

Access to CMS claims data thru Lightbeam

Identification of highest cost patients

Awareness of inpatient and SNF utilization

Page 13: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Our Story, continued…

Effective use of our EMR registry and report functions

Health Information Department – combines EMR and Billing staff

Improved working relationships:

Hospitals – MMMC-Alpena, TSJH, McLaren NM

Home care agencies – medical director is AHC provider

SNFs – our internist sees nearly all AHC pts

Strong physician champion who can effectively reach providers

Page 14: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Impact – Care Coordination

Expanded care coordination/care management to all pts

Strong Care Management Department leadership

High rate of patient enrollment in care management

RN Care Managers located at all sites

Patient self-management of chronic disease

5+ chronic conditions account for 80% of the cost

Coordination of care and services

Patient navigation of healthcare maze

Prevention of unnecessary ED use and hospitalizations

Transition of Care Management – GLHC provides ADT’s

Tele-Care Management

Page 15: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Care Coordination of the Sick & Expensive;

Wellness Visits for the rest

15

Page 16: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

The Care Model revisted!

Page 17: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Care Coordination, continued…

LPN Care Connectors

Work insurance lists to close gaps in care

Educate re: appropriate use of ED – letters, rack cards, fridge

magnets

Expanded care-team service delivery

Behavioral Health Consultants

Behavioral Health Patient Navigators

Community Health Workers

Page 18: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

ED Patient Education – Rack Card

!

Before you go to the Emergency Room!

Have you called our Alcona Health Center

provider on-call?

An AHC provider is available by phone for after-hours care: nights (5pm – 8am), weekends, and holidays.

Call Alpena Hospital at

356-7390

to contact the on-call provider for our patients.

Call the on-call provider for:

Cold or flu symptoms

Fever

High blood pressure

High or low blood sugar

Minor injuries, aches, pains

Changes in mood

Nausea, vomiting, diarrhea

Burning with urination

“I don’t feel right” (shaky, weak, dizzy)

Swelling of feet/ankles

Call 911 or go to the ER for:

Severe pain or headache

Chest pain

Signs of stroke

Difficulty breathing

Fainting or seizures

Major injuries (cuts, broken bones)

Bleeding that won’t stop or throwing up blood

Feeling suicidal

Page 19: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

ED Patient Education – Refrigerator Magnet

Page 20: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Impact – Annual Wellness Visits

AWV for all Medicare patients

Retrospective assignment precludes targeting assigned pts

Preliminary prospective assignment is a moving target

Use of EMR function (Clinical Events Manager) for Point-of-Service

reminders

Less staff time, e.g. calling from lists

Greater patient acceptance

Pre-visit assessment via phone by clinical support staff

More efficient use of time

Better prepared for the face-to-face visit

Page 21: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Annual Wellness Visits, continued…

Focus on evidence-based preventative care, e.g. USPSTF

Advanced Care Planning can be included

Capture clinical quality measures

Increase attribution numbers

Page 22: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Quality Measures

Multiple initiatives, grants, programs with their own requirements

“They-to-whom-we-must-report”

UDS, PCMH, MSSP, etc.

Consistency

Across sites – clinical support staff training

Across providers – peer training

Within EMR – work with system administrators

Clinical Quality Measures Crosswalk

Borrowed from Ohio Primary Care Association

Page 23: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Quality Measure Crosswalk

ADOLESCENT/ CHILDCARE PCMH UDS HEDIS MU MSSP MIPCT

ADHD Percentage of children 6-12 years of age and newly dispensed a medication for attention

deficit/hyperactivity disorder (ADHD) who had appropriate follow-up care YES YES

LEAD SCREENING Percentage of children 2 years of age who had one or more blood tests for lead poisoning by their 2 nd

birthday YES

PHARYNGITIS Percentage of children 2-18 years of age who were diagnosed with pharyngitis and dispensed an

antibiotic, and received a group A streptococcus test for the episode YES YES

UPPER RESPIRATORY INFECTION (URI) Percentage of children 3 months-18 years of age who were given a diagnosis of URI and were not

dispensed an antibiotic prescription YES YES

WELL CHILD EXAMS Access to care: Percentage of children and adolescents 12 months-19 years of age who had a visit with

a PCP. The measure reports on four separate percentages: Children 12-24 months who had a visit with

a PCP during the measurement year; Children 25 months-6 years who had a visit with a PCP during the

measure year prior to the measurement year; Adolescents 12-19 years who had a visit with a PCP

during the measurement year or the year prior to the measurement year

YES YES

Well-Child Visits in the First 15 Months of Life- Percentage of children who turned 15 months old during

the measurement year and had from no well-child visits to six well-child visits with a primary care

physician during their first 15 months of life

YES YES YES

>= 6 VISITS

Well-Child visits in the third, fourth, fifth, and sixth years of life- Percentage of children 3-6 years of age

who received one or more well-child visits with a primary care practitioner during the measurement

year

YES YES YES

Adolescent Well-Care Visit – Percentage of enrolled adolescents and your adults 12-21 years of age who

had at least one comprehensive well-care visit with a primary care practitioner or an OB/GYN

practitioner during the measurement year

YES YES

Percentage of children and adolescents 3-17 years of age who had an outpatient visit with a PCP or

OB/GYN during the measurement year and who had evidence of: BMI percentile documentation;

counseling for nutrition; counseling for physical activity

YES YES YES

Page 24: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Quality Measure Crosswalk

ASTHMA Asthma Treatment: percentage of patients with a diagnosis of persistent asthma (either mild, moderate, or severe) who were prescribed accepted pharmacologic therapy

YES YES YES YES

Medications Management: Percentage of people aged 5-64 years of age who were identified as having persistent asthma and were dispensed appropriate asthma controller medications that they remained on for at least 75% of their treatment period

YES (regardless of age)

YES

ATRIAL FIBRILLATION Percentage of time in which patients aged 18 and older with atrial fibrillation who are on chronic warfarin therapy have International Normalized Ratio (INR) test results within the therapeutic range during the measurement period

YES

BACK PAIN Percentage of patients 18-50 years of age with a diagnosis of low back pain who did not have an imaging study (plain X-ray, MRI, CT scan) within 28 days of the diagnosis

YES YES

BRONCHITIS Percentage of adults 18-64 years of age with a diagnosis of acute bronchitis who were not dispensed an antibiotic prescription

YES

CANCER Percentage of patient visits, regardless of patient age, with a diagnosis of cancer currently receiving chemotherapy or radiation therapy in which pain intensity is quantified

YES

BREAST CANCER Percentage of women 50-74 years of age who had at least one mammogram to screen for breast cancer in the past two years

YES YES (40-69)

YES YES 27 MONTHS

YES

Percentage of female patients aged 18 years and older with Stage IC through IIC, ER or PR positive breast cancer who were prescribed tamoxifen or aromatase inhibitor (AI) during the 12-month reporting period

YES

CERVICAL CANCER Percentage of patients 21-64 years of age who received one or more Pap tests to screen for cervical cancer

YES YES YES YES YES

COLORECTAL CANCER Percentage of patients 50-75 years of age who had appropriate screening for colorectal cancer

YES YES YES YES YES

Percentage of patients aged 18-80 years of age with AJCC Stage III colon cancer who are referred for adjuvant chemotherapy, prescribed adjuvant chemotherapy, or have previously received adjuvant chemotherapy within the 12-month reporting period

YES

PROSTATE CANCER

Page 25: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

2017 ACO Quality Measures

I 25

Timely Care

Provider Communication

Patient’s Rating of Provider

Access to Specialists

Health Promotion and Education

Shared Decision Making

Health Status/Functional Status

Stewardship of Pt. Resources

CARE COORDINATION & PT SAFETY Fall Risk

Medication Recon Post Discharge

AT RISK POPULATIONS Diabetes - A1c Poor Control

Diabetic Eye Exam

Hypertension Control

Aspirin for IVD

Depression Remission

PREVENTION Breast Cancer Screen

Colon Cancer Screen

Flu Vaccine

Pneumonia Vaccine

BMI

Tobacco Use

Depression Screen

Statin Therapy for CVD

PATIENT EXPERIENCE - ACO-CAHPS Survey

Claims Based

Use of Imaging for Low Back Pain

Unplanned Admissions – DM, HF, CC+

Readmissions – All conditions, SNF 30-day

Admissions – Ambulatory sensitive conditions

Use of Certified EHR (Meaningful Use)

Page 26: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Risk Adjustment

CMS compares the ACO’s spending to a benchmark:

an estimate of what FFS expenditures under Parts A & B would have

been in the absence of the ACO

Benchmark is adjusted

Patient demographics, e.g. age, gender

Level of risk

Page 27: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Risk Adjustment, continued…

Risk adjustment in the MSSP

Adjusts the benchmark based on the expected costs of assigned

beneficiaries

Is prospective – predicts future expenses based on diagnoses

from the prior year

Compares the benchmark to the actual expenditures for

beneficiaries assigned to the ACO in each performance year

The ACO will only receive shared savings if the expenditures are

lower than the benchmark

Page 28: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Risk Level

Diagnosis codes submitted on a claim – the primary way Medicare

assigns risk

Providers must accurately capture and code all relevant diagnoses,

i.e. chronic conditions, every year

Code to the highest ICD-10 specificity, complexity or severity

Diagnoses and treatment codes claimed should be supported by

documentation in the medical record (of course!)

Page 29: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Cost and Utilization for 2016

Risk-adjusted total expenditures

Alcona well below CMS benchmark, but trending up

Greater Michigan Rural ACO just above the benchmark

Inpatient discharges per 1,000

Alcona below the average for ACO and Caravan Health, but trending up

ACO saw an increase in PPPY cost, but decrease in discharges

Page 30: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Cost and Utilization, continued…

ED discharges

Alcona slightly above the ACO and CH averages, but trending down

ACO well above CH average, but trending down

SNF days per 1,000

Alcona below ACO and CH averages, and trending down

ACO cost and utilization well above CH average, but trending down

Page 31: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

NACHC Fact Sheet – May 2016

Health Centers and Medicare: Caring for America’s Seniors

Page 32: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Lessons and On-going Challenges

Ensure patients see a physician once a year

Impact on attribution

High mid-level to physician ratio

Keep patients in the community to achieve plurality of care

Expand same-day and after-hours access

Walk-in hours, especially at sites close to hospitals

Reduce ED utilization and preventable admissions

Care Management and Transition of Care Management

Patient education re: appropriate ED use

Educate providers re: ICD-10 coding and risk scoring

QI re: patient survey responses, and quality measure results

Page 33: Value-Based Payment...Michigan Primary Care Transformation (MiPCT) Demonstration Project 2011-2016 Bureau of Primary Health Care requirements for FQHCs Electronic charting and practice

Additional Resources

Fiesinger, T. Patient Attribution: Why It Matters More Than Ever. Family Practice Management, Nov/Dec 2016.

www.aafp.org/fpm

No Dollar Left Behind: Maximize Medicare Payments for Your Practice. Michigan Family Physician, Winter 2016-2017

www.mafp.com

CMS Specifications: Medicare Shared Savings Program, Shared Savings and Losses and Assignment Methodology, Applicable beginning Performance Year 2016, Version 4, December 2015