181.000 Incentives to Improve Care Quality,
Efficiency and Economy
A. Definitions
1. An "episode" refers to a defined
collection of related Medicaid-covered health care services provided to a
specific Medicaid beneficiary.
2.
An "episode type" is defined by a diagnosis, health care intervention, or
condition during a specific timeframe (or performance period).
3. "Thresholds" are the upper and lower
reimbursement benchmarks for an episode of care.
B. Medicaid has established a payment
improvement initiative ("payment improvement program") to incentivize improved
care quality, efficiency and economy. The program uses episode-based data to
evaluate the quality, efficiency and economy of care delivered in the course of
the episode, and to apply payment incentives. Please refer to the
Episodes of Care Medicaid Manual for information about specific
episodes.
C. The payment
improvement program is separate from, and does not alter, current methods for
reimbursement.
D. The payment
improvement program promotes efficiency, economy and quality of care by
rewarding high-quality care and outcomes, encouraging clinical effectiveness,
promoting early intervention and coordination to reduce complications and
associated costs, and, when provider referrals are necessary, by encouraging
referral to efficient and economic providers who furnish high-quality
care.
E. Ail medical assistance
provided in the delivery of care for an episode may be included in the
determination of a supplemental payment incentive under the payment improvement
program.
F. Payment incentives may
be positive or negative. Incentive payments are calculated and made
retrospectively after care has been completed and reimbursed in accordance with
the published reimbursement methodology. Incentive payments are based on the
aggregate of valid, paid claims across a provider's episodes and are not
relatable to any individual provider claim for payment.
G. Medicaid establishes episode definitions,
levels of supplemental incentive payments and appropriate quality measures
based on evidence-based practices. To identify evidence-based practices,
Medicaid shall consider clinical information furnished by Arkansas providers of
the care and services typically rendered during the episode of care, and may
also consider input from one or more quality improvement organizations
("QIO's") or QIO-like entities, peer-reviewed medical literature, or any
combination thereof.
H. Principal
Accountable Providers
The principal accountable provider(s) (PAPs) for each episode
is/are identified in the section defining the episode. In some cases, Medicaid
may identify PAPs after an episode is complete using algorithms described in
the episode definition.
I.
Supplemental Payment incentives
For each PAP for each applicable episode type:
1. Performance will be aggregated and
assessed over a specified period of time ("perfonmance period"). For each PAP,
the average reimbursement across all relevant episodes completed during the
perfomiance period will be calculated, based on the set of services included in
the episode definition published and made available to providers.
2. Some episodes may be excluded and
reimbursement for some episodes may be adjusted in this calculation, based on
clinical or other factors, as described in the definition of each
episode.
3. The average adjusted
reimbursement of all episodes for the PAP during the performance period will be
compared to thresholds established by Medicaid with advice frohi
providers.
4. If the average
adjusted episode reimbursement is lower than the commendable threshold and the
PAP has documented that the quality requirements established by Medicaid for
each episode type have been met, Medicaid will make a positive supplemental
payment to the PAP. This payment will be equal to the difference between the
average adjusted episode reimbursement and the commendable threshold,
multiplied by the number of episodes included in the calculation and multiplied
by a gain sharing percentage for the episode. Where necessary, a gain sharing
limit will be established to avoid incentives for underutilization. PAPs with
average adjusted episode reimbursement lower than the gain sharing limit will
receive a supplemental payment calculated as though their average adjusted
episode reimbursement were equal to the gain sharing limit.
5. If the average episode reimbursement is
higher than the acceptable threshold, the PAP will incur a negative
supplemental payment. This payment to Medicaid will be equal to the difference
between the acceptable threshold and the average adjusted episode
reimbursement, multiplied by the number of episodes included in the calculation
and multiplied by a risk sharing percentage defined by Medicaid for the
episode.
J. Principles
for determining "thresholds""
1. The threshold
process aims to incentivize high-quality clinical care delivered efficiently,
and to consider several factors including the potential to improve patient
access, the impact on provider economics and the level and type of practice
pattern changes required for performance improvement.
2. The acceptable threshold is set such that
average cost per episode above the acceptable threshold reflects unacceptable
performance, which could result from a large variation from, typical
performance without clinical justification (e.g., individual provider
variation) or from system-wide variance from widely accepted clinical
standards.
3. The commendable
threshold is set such that outperforming the commendable threshold represents
quality care provided at a lower total reimbursement, which would result from
care at meaningfully better than current average reimbursement in Arkansas,
consistent with good medical outcomes. Medicaid may take into consideration
what a clinically feasible target would be, as demonstrated by historical
reimbursement variance in Arkansas.
4. The gain-sharing limit is set to avoid the
risk of incentivizing care delivery at a cost that could compromise
quality.
5. The gain and risk
sharing percentages aim to recognize required provider investment in practice
change and will be set at a sustainable level for Medicaid.
K. Outlier Patient Exclusions
Calculation of average adjusted episode reimbursement for each
PAP will exclude outlier patients who have extraordinarily high risk/severity
so that one or a few cases do not meaningfully misrepresent a provider's
performance across the provider's broader patient population.
L. Provider-level adjustments
1. Supplemental payment incentives for each
PAP take into account provider-level adjustments, which may include stop-loss
provisions, adjustments for cost-based facilities, adjustments or exclusions
for providers with low case volume or any combination thereof.
2. Stop-loss protection: Unless provided
otherwise for a specific episode of care, a provider's net negative incentive
adjustment (total positive adjuistments minus total negative adjustments) for
all episodes of care adjustments made during any calender year shall
notexceedjen percent (10%) of the provider's gross Medicaid reimbursements
received by the provider during that calender year.
3. Temporary stop-loss provisions may apply
when necessary to ensure access to care.
4. Providers that receive cost-based or
PPS-based reimbursement are reimbursed as specified in the corresponding
provider manuai(s), but are subject to positive and negative supplemental
payment incentives in order to achieve statewide improvement in quality and
efficiency. For episodes including services furnished by providers who receive
at exceptional reimbursement levels, reimbursements attributed to PAPs for the
purpose of calculating performance are computed as if the provider did not
receive exceptional reimbursement.
5. Minimum case volume thresholds exclude
from supplemental payment incentives those providers whose case volume includes
too few cases to generate a robust measure of performance. Medicaid will set a
minimum case volume for each episode type. PAPs who do not meet the minimum
case volume for an episode type will not be eligible for positive or negative
supplemental payments for that episode type.
M. Quality
1. For each episode type, there will be a set
of quality metrics "to pass" and a set of quality metrics "to track." These
quality metrics may be based on claims data or based on additional data
specified by Medicaid, which PAPs will be required to report.
2. To qualify for positive supplemental
payments, PAPs must report all required data and meet specific thresholds for
the quality metrics "to pass."
3.
Providers who do not report data or who do not meet minimum quality thresholds
may still incur negative supplemental payments if their average adjusted
episode reimbursement exceeds the acceptable threshold.
N. Consideration of the aggregate cost and
quality of care is not a retrospective review of the medical necessity of care
rendered to any particular patient, nor is such consideration intended to
supplant any retrospective review or other program integrity activity.
METHODS AND STANDARDS FOR ESTABLISHING PAYMENT RATES
-INPATIENT HOSPITAL SERVICES
ATTACHMENT 4.19-A
1. Inpatient Hospital Services
A.
INCENTIVES TO IMPROVE CARE QUALITY,
EFFICIENCY, AND ECONOMY
2.
Negative Incentive
Adjustments: If the average adjusted episode of care paid claims
are higher than the acceptable direshold, the PAP will remit to Medicaid the
difference between the acceptable threshold and the average adjusted episode
reimbursement, multiplied by the number of episodes included in the
calculation, multiplied by 50% or the risk sharing percentage specified for the
episode of care. Unless provided otherwise for a specific episode of care, a
provider's net negative incentive adjustment (total positive adjustments minus
total negative adjustments) for all episode of care adjustments
made during any calendar year shall not exceed ten percent
(10%) of the provider's gross Medicaid reimbursements received by the
provider during that calendar year.
2.
b. Rural
Health Clinic Services and other ambulatory services that are covered under the
plan and furnished by a rural health clinic
A.
ALTERNATE PAYMENT METHODOLOGY TO
INCENTIVES TO IMPROVE CARE QUALITY, EFFICIENCY, AND ECONOMY
IV.
INCENTIVE ADJUSTMENTS:The
Program promotes efficient and economic care utilization by making incentive
adjustments based on the aggregate valid and paid claims ("paid claims") across
a PAP's episodes of care ending during the twelve (12) month performance period
specified for the episode. Unless provided otherwise for a specific episode of
care, incentive adjustments are made annually in the form of gain sharing
(positive incentive adjustments) or provider risk sharing payments to Medicaid
(negative incentive adjustments), and equal 50% of the difference between the
average adjusted episode expenditures and the applicable threshold as described
below. Incentive adjustments will occur no later tiian ninety (90) days after
the end of the performance period. Because the incentive adjustments are based
on aggregated and averaged claims data for a particular performance period,
adjustments cannot be apportioned to specific provider claims.
1.
Positive Incentive
Adjustments: If the PAP's average adjusted episode paid claims are
lower than the commendable threshold and the PAP meets the quality requirements
established by Medicaid for each episode type, Medicaid will remit an incentive
adjustment to the PAP equal to the difference between the average adjusted
episode reimbursement and the commendable threshold, multiplied by the number
of episodes included in the calculation, multiplied by 50% or the gain sharing
percentage specified for the episode of care. To avoid incentivizmg
underutilization, Medicaid may establish a gain sharmg limit. PAPs with average
adjusted episode expenditures lower than the gain sharing limit will receive an
incentive adjustment calculated as though the PAP's average adjusted episode of
care paid claims equal the gain sharing limit.
2.
Negative Incentive
Adjustments: If the average adjusted episode of care paid claims
are higher than the acceptable threshold, the PAP will remit to Medicaid the
difference between the acceptable threshold and the average adjusted episode
reimbursement, multiplied by the number of episodes included in the
calculation, multiplied by 50% or the risk sharing percentage specified for the
episode of care. Unless provided otherwise for a specific episode of care, a
provider's net negative incentive adjustment (total positive adjustments minus
total negative adjustments) for all episodes of care during any performance
period shall not exceed ten percent (10%) of the provider's gross Medicaid
reimbursements during that performance period.
For Rural Health Centers (RHCs), the negative incentive
adjustment will not result in payment at less than the rate required under the
PPS methodology, but Medicaid reserves the right to adjust total reimbursements
to RHCs based on appropriate utilization under our utilization control
responsibility to safeguard against unnecessary or inappropriate use of
Medicaid services and against excess payments consistent with regulations at 42
CFR Part 456.
2.
a. Outpatient Hospital Services ]
A.
INCENTIVES TO IMPROVE CARE QUALITY,
EFFICIENCY, AND ECONOMY 2.
Negative Incentive Adjustments: If the average
adjusted episode of care paid claims are higher than the acceptable threshold,
the PAP will remit to Medicaid the difference between the acceptable threshold
and the average adjusted episode reimbursement, multiplied by the number of
episodes included in the calculation, multiplied by 50% or the risk sharing
percentage specified for the episode of care. Unless provided otherwise for a
specific episode of care, a provider's net negative incentive adjustment (total
positive adjustments minus total negative adjustments) for all episode of care
adjustments made during any calendar year shall not
exceed ten percent (10%) of the provider's gross Medicaid reimbursements
received by the provider during that calendar
year.
5. Physicians' Services
A.
INCENTIVES TO IMPROVE CARE QUALITY,
EFFICIENCY, AND ECONOMY
2.
Negative Incentive Adjustments: If the average
adjusted episode of care paid claims are higher than the acceptable threshold,
the PAP will remit to Medicaid the difference between the acceptable threshold
and the average adjusted episode reimbursement, multiplied by the number of
episodes included in the calculation, multiplied by 50% or the risk sharing
percentage specified for the episode of care. Unless provided otherwise for a
specific episode of care, a provider's net negative incentive adjustment (total
positive adjustments minus total negative adjustments) for all episode of care
adjustments made during any calendar year shall not
exceed ten percent (10%) of the provider's gross Medicaid reimbursements
received by the provider during that calendar
year.
2.
b. Rural Health Clinic Services and other
ambulatory services that are covered under the plan and furnished by a rural
health clinic
A.
ALTERNATE PAYMENT METHODOLOGY TO
INCENTIVES TO IMPROVE CARE QUALITY, EFFICIENCY, AND ECONOMY
I.
PURPOSE: In order to assure
that Medicaid funds are used to purchase medical assistance efficiently and
economically (quality services of the right kind and mix), Medicaid has
established a payment improvement initiative ("Payment Improvement Program," or
"Program"). The Program:
1. Establishes
Principle Accountable Providers ("PAPs") for defined episodes of
care;
2. Uses episode-based data to
evaluate the quality, efficiency and economy of care delivered in the course of
the episode of care, and to apply incentive adjustments;
3. Incentivizes improved care quality,
efficiency and economy by rewarding high-quality care and outcomes;
4. Encourages clinical
effectiveness;
5. Promotes early
intervention and coordination to reduce complications and associated costs;
and
6. When provider referrals are
necessary, encourages referral to efficient and economic providers who furnish
high-quality care.
Complete details including technical information regarding
specific quality and reporting metrics, performance thresholds and incentive
adjustments are available in the Episodes of Care Medicaid Manual available at
https://www.medicaid.state.ar.us/lntemetSolution/Provider/docs/docs.a5px
and also at the Arkansas Health Care Payment Improvement Initiative website at
http://www.p3vmentinitiative.org/Pages/defautt.aspx.
II.
NOTICE and
AMENDMENTS: The Program and Program amendments are subject to review and
approval by the Centers for Medicare and Medicaid Services (CMS). Rules
establishing the Program are adopted in compliance with the Arkansas
Administrative Procedure Act, Ark. Code Ann. §
25-15-204. Except in cases of
emergency as defined in Ark. Code Ann. §
25-15-204(e)(2)(A),
providers will receive at least 30-days written notice of any and all changes
to the Episodes of Care Medicaid Manual and State Plan pages.
III.
MEDICAID PAYMENTS: Subject
to the incentive adjustments described below, providers, including PAPs,
furnish medically necessay care to eligible beneficiaries and are paid in
accordance with the published Medicaid reimbursement methodology in effect on
the date of service.
2.
b. Rural Health Clinic Services and other
ambulatory services that are covered under the plan and lumished by a rural
health clinic
A.
ALTERNATE PAYMENT
METHODOLOGY TO INCENTIVES TO IMPROVE CARE QUALITY, EFFICIENCY, AND ECONOMY
V.
APPLICATION: Complete details
including technical information regarding specific quality and reporting
metrics, performance thresholds and incentive adjustments are available in the
Episodes of Care Medicaid Manual available at https://\vww.medi caid.
statcar.us/l ntemetS olution/Provid er/docs/docs .aspx and also at the Arkansas
Health Care Payment Improvement Initiative website at http: //www
.pavmentinitiati ve.Qrg/Pages/default .aspx.
Effective for dates of service on or after October 1, 2012, the
defmed scope of services within the following episode(s) of care are subject to
incentive adjustments:
(1)
Perinatal Care Episodes
Effective for dates of service on or after October 1, 2013, the
defmed scope of services within the following episode(s) of care are subject to
incentive adjustments:
(1)
Acute
Exacerbation of Clironic Obstructive Pulmonary Disease (COPD)
Episodes
(2)
Acute
Exacerbation of Asthma Episodes
Effective for dates of service on or after March 14, 2014, the
defmed scope of services wathin the following episode(s) of care are subject to
incentive adjustments:
(1)
Acute Ambulatory Upper Respiratory Infection (URI) Episodes
4.
b. Early
and Periodic Screening and Diagnosis of Individuals Under 21 Years of Age and
Treatment of Conditions Found
(17) Psychology
Services
A.
INCENTIVES TO IMPROVE CARE
QUALITY, EFFICIENCY, AND ECONOMY
IV.
INCENTIVE ADJUSTMENTS
1.
Positive Incentive
Adjustments: If the PAP's average adjusted episode paid claims are
lower than the commendable threshold and the PAP meets the quality requirements
established by Medicaid for each episode type, Medicaid will remit an incentive
adjustment to the PAP equal to the difference between the average adjusted
episode reimbursement and the commendable threshold, multiplied by the number
of episodes included in the calculation, multiplied by 50% or the gain sharing
percentage specified for the episode of care. To avoid incentivizing
underutilization, Medicaid may establish a gain sharing limit. PAPs with
average adjusted episode expenditures lower than the gain sharing limit will
receive an incentive adjustment calculated as though the PAP's average adjusted
episode of care paid claims equal the gain sharing limit.
2.
Negative Incentive
Adjustments: If the average adjusted episode of care paid claims
are higher than the acceptable threshold, the PAP will remit to Medicaid the
difference between the acceptable threshold and the average adjusted episode
reimbursement, multiplied by the number of episodes included in the
calculation, multiplied by 50% or the risk sharing percentage specified for the
episode of care. Unless provided otherwise for a specific episode of care, a
provider's net negative incentive adjustment (total positive adjustments minus
total negative adjustments) for all episode of care
adjustments
made during any
calendar year shall not exceed ten percent
(10%) of the provider's gross Medicaid reimbursements
received by the
provider during that
calendar year.
23. Any other medical care and any other type
of remedial care recognized under State law, specified by the Secretary.
e. Emergency Hospital Services
A. INCENTIVES TO IMPROVE CARE QUALITY,
EFFICIENCY, AND ECONOMY
2.
Negative Incentive
Adjustments: If the average adjusted episode of care paid claims
are higher than the acceptable threshold, the PAP will remit to Medicaid the
difference between the acceptable threshold and the average adjusted episode
reimbursement, multiplied by the number of episodes included in the
calculation, multiplied by 50% or the risk sharing percentage specified for the
episode of care. Unless provided otherwise for a specific episode of care, a
provider's net negative incentive adjustment (total positive adjustments minus
total negative adjustments) for all episode of care adjustments made during any
calendar year shall not exceed ten percent (10%) of the provider's gross
Medicaid reimbursements received by the provider during that calendar year.
23. Any other medical care and any other type
of remedial care recognized under State law, specified by the Secretary.
f. Critical Access Hospitals (CAH)
A. INCENTIVES TO IMPROVE CARE QUALITY,
EFFICIENCY, AND ECONOMY
2.
Negative Incentive
Adjustments: If the average adjusted episode of care paid claims
are higher than the acceptable threshold, the PAP will remit to Medicaid the
difference between the acceptable threshold and the average adjusted episode
reimbursement, multiplied by the number of episodes mcluded in the calculation,
multiplied by 50% or the risk sharing percentage specified for the episode of
care. Unless provided otherwise for a specific episode of care, a provider's
net negative incentive adjustment (total positive adjustments mdnus total
negative adjustments) for all episode of care adjustments made during any
calendar year shall not exceed ten percent (10%) of the provider's gross
Medicaid reimbursements received by the provider during that calendar year.
13. Other diagnostic, screening, preventive
and rehabilitative services, i.e., other than those provided elsewhere in this
plan
(d) Rehabilitative Services
(1) Rehabilitative Services for Persons with
Mental Illness (RSPMI)
A.
INCENTIVES TO
IMPROVE CARE QUALITY, EFFICIENCY, AND ECONOMY
IV.
INCENTIVE ADJUSTMENTS :
1.
Positive Incentive
Adjustments: If the PAP's average adjusted episode paid claims are
lower than the commendable threshold and the PAP meets the quality requirements
established by Medicaid for each episode type, Medicaid will remit an incentive
adjustment to the PAP equal to the difference between the average adjusted
episode reimbursement and the commendable threshold, multiplied by the number
of episodes included in the calculation, multiplied by 50% or the gain sharing
percentage specified for the episode of care. To avoid incentivizing
xmderutilization, Medicaid may establish a gain sharing limit. PAPs with
average adjusted episode expenditures lower than the gain sharing limit will
receive an incentive adjustment calculated as though the PAP's average adjusted
episode of care paid claims equal the gain sharing limit.
2.
Negative Incentive
Adjustments: If the average adjusted episode of care paid claims
are higher than the acceptable threshold, the PAP will remit to Medicaid the
difference between the acceptable threshold and the average adjusted episode
reimbursement, multiplied by the number of episodes included in the
calculation, multiplied by 50% or the risk sharing percentage specified for the
episode of care. Unless provided otherwise for a specific episode of care, a
provider's net negative incentive adjustment (total positive adjustments minus
total negative adjustments) for all episode of care
adjustments
made during any
calendar year shall not exceed ten percent
(10%) of the provider's gross Medicaid reimbursements
received by the
provider during that
calendar year.
27. Advanced Practice Nurse and Registered
Nurse Practitioner licensed as such by the Arkansas State Board of Nursing.
A.
INCENTIVES TO IMPROVE CARE QUALITY,
EFFICIENCY, AND ECONOMY
2.
Negative Incentive Adjustments: If the average
adjusted episode of care paid claims are higher than the acceptable threshold,
the PAP will remit to Medicaid the difference between the acceptable threshold
and the average adjusted episode reimbursement, multiplied by the number of
episodes included in the calculation, multiplied by 50% or the risk sharing
percentage specified for the episode of care. Unless provided otherwise for a
specific episode of care, a provider's net negative incentive adjustment (total
positive adjustments minus total negative adjustments) for all episode of care
adjustments made during any calendar year shall not
exceed ten percent (10%) of the provider's gross Medicaid reimbursements
received by the provider during that calendar
year.