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.
- 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.
