CMMI Appears to Embrace Ideas Outlined in LTSS/ACO White Paper

April 04, 2024

BY Nicole Fallon

Recommend

CMMI's updated specialty care strategy appears to embrace some suggestions from new white paper from a group of provider and Accountable Care Organization groups.

LeadingAge along with other post-acute care provider partners have been working for many years to convince the Center for Medicare and Medicaid Innovation (CMMI) to create opportunities for aging service providers to participate in a meaningful way in the various alternative payment and care delivery models it is developing and testing. Based upon a recent post in Health Affairs where CMMI provides 2024 updates to its specialty care strategy, our efforts appear to finally be getting some attention.

The 2024 CMS CMMI update of its strategy to support person-centered, value-based specialty care may hold hints at future opportunities for post-acute care and long term care providers to play a more meaningful role in accountable care and alternative payment models. In addition, the updates also suggest CMS and CMMI are considering new approaches that align with recommendations we made to CMMI, in coalition with other provider and accountable care organization stakeholders, in a February 2024 meeting. During that meeting, we shared ideas outlined in the stakeholder group's "Considerations for Long Term Care Providers Participating in Value-Based Care Models" white paper.

CMMI has identified a goal to have all Medicare beneficiaries in an accountable care relationship by 2030 and accountable care organizations as the primary model through which it intends to improve beneficiary outcomes and lower costs. Our white paper explains current barriers to long term care and post-acute care providers being meaningfully engaged in these ACO models and long-term care residents being included. We walked through the key issues and recommendations from the white paper showing CMMI a path to more Medicare beneficiaries being tied to a successful accountable care relationship.

Currently, long-stay nursing home residents are misaligned to ACOs because that alignment is based upon where the beneficiary received primary care when they still lived independently in the community. Once they move to a long-stay nursing home, the source of their primary care often changes but they remain in the previous ACO but don't receive the full benefit of being in an ACO.

We identified policy steps CMMI could take to more appropriately align these individuals with an ACO that is working in partnership with the nursing home. In addition, we encourage CMMI to test an embedded bundled payment for nursing homes within the ACO allowing the nursing home to share in some of the savings generated from better care coordination for their residents.

It appears this idea might have resonated with CMMI staff as its April 2 strategy update includes a similar reference under its fourth strategic element - Create Financial Incentives for Specialists To Affiliate With Population-Based Models and Move to Value-Based Care. Here it states, "The Innovation Center is exploring several options that could be embedded in future population-based models, including developing subpopulation targets that facilitate new payment approaches for high volume or high-cost condition."

In addition to recommendations on how to better align beneficiaries, the white paper also provides suggestions on: needed changes to ACO financial methodology to make it more desirable to enroll nursing home residents and others requiring long-term services and supports; the need to develop quality metrics appropriate for a long-term care population; and data needed by providers and ACOs to improve and coordinate care for ACO beneficiaries.

The white paper was produced from a series of roundtable discussions that LeadingAge and others participated in in August 2023, The National Association of Accountable Care Organizations (NAACOs) and the American Health Care Association convened the following organizations who contributed to the work: Advion, American Health Insurance Plans, American Hospital Association, American Medical Rehabilitation Providers Association, ATI Advisory, Bloom Healthcare, Cardon & Associates, CareConnect MD, Families USE, Health Care Transformation Task Force, KNG Health Consulting, LeadingAge, Long-Term Care ACO, National Association for Home and Hospice Care, National Health Care Associates, Premier, Society for Post Acute and Long Term Care Medicine, SNP Alliance, and Village MD.