6 Ways To Prepare Your Hospice For The Primary Care First Application

Setting yourself up for application acceptance and ongoing success

by Jeremy Powell, CEO of Acclivity Health

The Centers for Medicare & Medicaid Services’ Primary Care First (PCF) model is rolling out in 2020, and applications will become available in a matter of weeks. The Seriously Ill Population (SIP) model under PCF is designed to improve care for high-need, high-risk patients who currently receive fragmented or inadequate care. To do this, CMS will assign SIP patients to participating hospice programs, paying the providers to coordinate their care and avoid unnecessary hospitalizations.

There are numerous benefits to hospices participating in the SIP program, but first, your application must be accepted. Hospices interested in participating should take time to adequately prepare for their application based on what is known about the PCF program’s criteria and past CMS applications.

1. Begin drafting responses to narrative applications now.

While the application has not been released yet, because Primary Care First is based on CPC+, the applications are likely to be similar. As with all Alternative Payment Model (APM) applications, it will likely feature a combination of check boxes and narrative answers about your organization, asking how you’ll meet the eligibility requirements and drive success in the program. By preparing responses to narrative questions in advance, you give yourself time to have them reviewed by experts on APMs and improve them as needed.

2. Prepare to analyze patient data provided by CMS.

Although CMS has not announced what types of patient information will be available to participating hospices — which will likely come once the application is approved but before signing the participation agreement — hospices will need a way to make sense of that data. A data analysis platform can provide a glimpse into what 2020 will look like for your hospice, including estimates of the number of patients being assigned to you, their acuity, their prognosis, and more.

3. Determine staffing needs based on the new influx of SIP patients.

By participating in the SIP program, hospices should be able to earn 20 to 25% net profit margins caring for SIP patients. To achieve this, plan for staffing adjustments required to meet the demands of the SIP program. Hospices already employ a multidisciplinary staff to meet patients’ needs; you may only need to redistribute your staff to reflect the forthcoming patient population in your care.

4. Review your technology against PCF’s criteria, including EHR, analytics, and reporting requirements.

To participate in the SIP program, CMS requires a hospice to make use of technology to support care delivery. From certified EHR platforms, to Health Information Exchanges (HIEs), to analytics capabilities, hospices will need to prove to CMS that they are able to make data-driven decisions about a population. Most hospices have never faced this requirement before and may find themselves without a clear path to success, so identifying these gaps as soon as possible is crucial.

5. Reach out to potential community partners to fill care delivery gaps (if any).

Hospices in the SIP program must prove they have a network of providers in the community that can help meet the needs of their patients. While many hospices already offer care coordination, those who currently do not should start engaging in those relationship-building conversations with other providers in the community. This will ensure patients have access to the right care, at the right time, in the right place.

6. Prepare for discussions with Medicare Advantage payers who opt into the program.

With the hospice carve-in looming, hospices need to start thinking about how they will interact with Medicare Advantage payers. SIP is a great first step. Because CMS has made PCF and SIP a multi-payer model, Medicare Advantage payers are invited to participate. Consider how you will hold meaningful discussions with these payers about partnering with them on SIP. Even though the Medicare Advantage payers’ version of the SIP program will be similar to CMS’s, there will be differences, and you’ll need a plan about how you negotiate the details.

For more information about how to prepare for the application, or how Primary Care First’s SIP program can benefit hospice programs, visit acclivityhealth.com/primarycarefirst.

• NHPCO Members: SIP Webinar from Edge Business SeriesJoin NHPCO for a free webinar on Friday, November 15 at 2:00 pm EST focusing on the recently released Request for Applications for the Primary Care First – Seriously Ill Population model. We will provide a detailed overview of the RFA and how hospices and palliative care organizations can be best prepared to apply and participate. We will also explore hospices’ readiness to provide SIP programming as well as the specific areas for providers to address to take advantage of this opportunity. NHPCO members are invited to register online.