DOH Work Group Discusses Revisions to Value-Based Payment Roadmap
The Department of Health’s (DOH) Value-Based Payment (VBP) Work Group met on May 10th to discuss plans for the final year of the State’s Medicaid VBP Roadmap. The meeting covered VBP in mainstream managed care, Health and Recovery Plan (HARP), and managed long term care (MLTC) programs and focused on proposed revisions to the Medicaid VBP Roadmap. The slides from the Work Group meeting are here.
The proposed Roadmap revisions that affect partially-capitated MLTC, Medicaid Advantage Plus (MAP), and Fully Integrated Duals Advantage (FIDA) plans and Programs of All-Inclusive Care for the Elderly (PACE programs) include the following:
Social Determinants of Health (SDH): The Roadmap will continue to require managed care plans engaged in Level 2 or Level 3 VBP arrangements to implement an SDH intervention and contract with a community-based organization (CBO) that does not bill Medicaid (a "Tier 1 CBO"). The proposed modifications to the SDH requirement include:
- Authorizing “third-party investors,” including foundations and venture capital funds, to provide financial support for SDH interventions.
- Adding a requirement that funding provided for SDH interventions must be appropriate for the size, scope, and specifications of the project.
- Authorizing expenditures for SDH interventions to be included in the “Other Medical” section of the MMCOR or MLTCRR reports.
- Adding a requirement for plans to share data with CBOs engaged in SDH interventions so that they can understand the target population and improve quality.
- Adding a requirement for plans to submit an SDH Intervention Status Report annually. The State will also request member-level data to evaluate the impact of SDH interventions on outcomes and savings.
LeadingAge NY noted once again the lack of funding for SDH interventions in MLTC rates or via stimulus and questioned the existing Roadmap provision requiring upfront funding for SDH interventions.
MLTC, MAP, PACE, and FIDA: The proposed revisions generally align the Roadmap with previously issued policy directives, including:
- Inserting the existing definitions of MLTC Level 1 and Level 2 VBP arrangements.
- Clarifying that under Level 2 arrangements, the potential "risk" allocated to the provider must be at least 1 percent of total annual expenditures between the plan and the provider. Level 2 contracts must include the Potentially Avoidable Hospitalization (PAH) measure and at least one additional approved measure, an SDH intervention, and a contract with a CBO. The proposed revisions also specify that financial incentives must be passed from the State to the Plan and from the Plan to the Provider.
- Clarifying that requirements for FIDA, MAP, and PACE are the same as those for mainstream plans.
LeadingAge NY noted the “square peg-round hole” problems that can arise when mainstream plan requirements are imposed indiscriminately on MLTC, MAP, PACE, and FIDA programs.
In addition to briefing participants on proposed revisions to the Roadmap, DOH provided an update on VBP penetration in managed care generally and MLTC specifically based on VBP Tracking Report (VBPTR) reporting. The Department noted that 79.8 percent of partially-capitated MLTC, MAP, PACE, and FIDA payments were captured in VBP Level 1 arrangements through Dec. 31, 2018. Three percent of MLTC, MAP, PACE, and FIDA payments were in VBP Level 3 arrangements (global capitation with a quality component). These Level 3 arrangements were likely PACE programs which are deemed Level 3. There was no reported spending in VBP Level 2 arrangements through MLTC. Based on these findings, the State will meet its 2019 goal of at least 50 percent of MLTC expenditures in Level 1 VBP and is within sight of the goal of at least 5 percent of expenditures in Level 2 or higher.
The meeting included the results of a DOH analysis of the quality measures selected for VBP contracts in the mainstream program and the nature of those arrangements. LeadingAge NY asked for a similar analysis of MLTC VBP contracts.
Finally, the Department provided a preview of its goal for the next phase of VBP. The next phase will focus on strengthening the integration of networks in the primary, acute, behavioral health, and long term care sectors.
The current Roadmap is available here. A redline version of the proposed revisions is available here. Comments on the Roadmap revisions are due by May 24th and should be submitted here and here. LeadingAge NY members that would like their comments included in the LeadingAge NY submission should provide their input by May 21st here.
Contact: Karen Lipson, firstname.lastname@example.org, 518-867-8383 ext. 124