Robert Sowislo   AAHCM Public Policy Committee

Robert Sowislo

 AAHCM Public Policy Committee

©AAHCM

Academy Public Policy

Year

in Review

and

Issues

for

Your Practice and the Field in Years Ahead

No Disclosures©AAHCMDisclosures

©AAHCMPublic Policy CommitteeLinda DeCherrie, MDBruce Kinosian, MDKarl Eric DeJonge, MDMichael Benfield, MDWilliam Mills, MDRodney Hornbake, MDThomas Edes, MD

Norman Vinn, DORobert Sowislo, MBAGeorge Taler, MDSteve Landers, MDJames Pyles, Esq. Connie Row, Executive Director AAHCM

Gary Swartz, Esq.

What does public policy mean for Academy Members – for a house call practice?How does Academy public policy and advocacy work occur?Public policy issues and demands now track transition from FFS to Value Based payment/population health management Current and future issues important to the field©AAHCM

AAHCM Public Policy

Refers to the laws, the actions of government, the agency funding priorities, and the regulationsImpacts your Practice organization and operation Practice revenue and success

©AAHCM What

does public policy mean for Academy Members – for a house call practice

Service provided by volunteer public policy committee and Academy staffRelationships with alliances, coalitions and multi-specialty groupsAugmented through Professional Services relationships ($)Law/lobbying, data analytics

Augmented through organizational relationships Corporate and professional alliances (AGS, AAHPM, etc.)

Supported through practice level and individual voluntary action

Letters/E-mail, calls, visits, political support and letters to editor/journals©AAHCM

How does Academy

public policy

work

occur?

©AAHCM

Policy area/issueAcademy effort and resultsTraditional Fee Schedule

SGR – supported permanent repeal and signed onto letters, (offered IAH)

CCM -  advocated for chronic care management code and successful in changes to make it more usable for

housecalls (incident to relaxed and business cost increasing requirements generally dropped)

ACP

– advocating for coverage and payment for advanced care planning effective 2016 – Dr. DeCherrie representing Academy

These two services (CCM and ACP) may produce value for Academy members that is greater as a ratio to practice service and revenue than for MDs/NPs and PAs in other practice settings. 

Professional Fee Schedule

Home Health - payment rule and conditions of participation, face to face requirements

, templates

Medicare Advantage/Advance Call Letter, and other letters regarding managed care

Shared Savings Programs (ACOs),

CMMI Request for Information  Re Advanced Primary Care Models

Impact Act 

Valu

e Base Payment Modifier/risk adjustment for high risk patients

Standards Development

Telemedicine

Academy Comment Letters, and face to face meetings with CMS officials

and Congressional staff

Restrictive requirements eliminated (PCMH for CCM)The Academy commented on an increased number and range of rule making and requests for comments and information as the impact of home care medicine is recognized and Academy capacity grows. Academy comments have been incorporated into final rules and policy. (Dr. Lauders leading)Waiver recommendations included in ACO developmentHome continues as location of service for Medicare Advantage assessments, diagnostic code acceptance. Patient attribution rules to include NP / PA, etc. Public Policy Committee responsePublic Policy Committee responseMeeting with MEDPAC. (Dr. Kinosian leading)AAHCM Standards Committee FormedAAHCM developed position paper on telemedicine for HBPC

2014-2015 Services and Outcomes

©AAHCMPolicy area/issueAcademy effort and results

Independence at Home Academy “JEN analysis” of risk adjustment for IAH like population has been accepted within CMS and will inform HCC risk adjustment

for Independence at Home. Academy will advocate that results be incorporated across all payment models, measures and the value based payment modifier program.

Advocacy toward continuation/expansion.

Advocate for accurate evaluation and payment

Managed Care

and Dual Eligibles

The Academy is increasing the depth and breadth of managed care industry relationships. This includes relationships with executives and medical leadership of health plans as well as the representatives/trade associations and regulators of health plans. 

Regulation, Audits, and

Practice Burden

The Academy continues to have influence in reducing practice burden

and in protecting and expanding opportunities for housecalls. Continued audit intervention.

Publications,

Media Request

s, and

Letters to the Editor , etc.

Academy

members have produced i

ncreased number of peer review articles, Academy

board and staff have responded to increase

level of requests for interviews regarding home care medicine and generated an increased number

of l

etters to the editor2014-2015 Services and Outcomes

Public policy issue of importance to your practice Fee for service volume/code based issuesValue based payment and alternative payment models (APMs) issuesPatient volume – how is patient relationship established? “Attribution”

No requirements, other than medical necessity and PCP relationship (unless preventive/screening)

Patient eligibility criteria/ attribution, so; Need to influence the rules for patient assignment to your practice – otherwise threat to patient panel

Standards – what standards required to render service as primary care provider?

None

,

other than basic state licensure, and Medicare program enrollment

Present

in MACRA for APMS and “medical home,” so;

Need to influence what will be the standards and who certifies the practices

.Measures and outcomes

Multiplicity of measures,

not population based

No outcomes requirements und

Present

in MACRA for professional fee schedule, APMS and “medical home,” so;

Need to influence what will be population appropriate measures and outcomes

©AAHCM

Academy public policy will have to mirror the transition from FFS to VBP

Public policy issue of importance to your practice Fee for service volume/code based issuesValue based payment and alternative payment models (APMs) issuesServices recognized and covered for payment

Coverage, payment and RVUs “fought” for on code by code basis, e.g.,

RVUs for house call E and M codes

TCM

CCM

ACP

AWV in home setting

Need to participate to negotiate definition of deal,

and

what is the righ

t bundle/risk/shared savings?

and

How to keep the budget/deal from shrinking in the future.

Payment

and measure assessment risk adjusted based on patient condition?

No.

Yes.

Need to influence in order to assure accurate risk adjustment for house call patient population regardless of payment model

Accountability – protection

against over and underutilization

The micromanagement,

burden and “hassle factor”

Fraud and abuse concerns and Audits and medical record review Will be embedded in evolving models based on outcomes and patient satisfaction. So, need to influence; Who establishes/administers waivers?Who controls patient movement across settings? Who evaluates outcomes and patient satisfaction? “Stark Exceptions”©AAHCMAcademy public policy will have to mirror the transition from FFS to VBP

Patient Enrollment /payment sourceExamples of Academy public policy efforts and influence requirementWhere will public policy efforts be required?Medicare fee for serviceNew services considered and covered –

e.g., Advance care planning Congress, CMSMedicare AdvantageHome continues as setting and focus for care coordination and care management

Eliminate barriers to house call contracting and NP credentialing

Risk adjustment Congress, CMS

Medicare ACOs/shared savings

and bundled payments

Beneficiary characteristics

Beneficiary attribution

Risk adjustment

Risk/shared savings, bundled payment “deal”

Congress,

CMS

Dual

eligibles and Medicaid Managed Care

Role

of house calls in population networks

Beneficiary enrollment

Opt in or out?

Payment terms

and levels

Congress, CMS, and

States;

Legislative

Medicaid/Health Departments

Insurance departmentsCommercial health plansBeneficiary enrollment “Attribution and Engagement”Eliminate barriers to house call contracting Eliminate barriers to NP credentialing Address plans requirement for PCMHCongress, CMS, and States;LegislativeMedicaid/Health DepartmentsInsurance departmentsNAIC, NGAMedicaid Beneficiary enrollment in ACOs, IAH like models adopted by MCOsStraight Medicaid l

evels

of payment need to move to Shared Savings

Congress, CMS, and

S

tates;

Legislative

Medicaid/Health Departments

©AAHCM

Academy public policy efforts will have to expand to mirror the migration of house call population to Medicare/Medicaid commercial plans