142.900
Principal
Accountable Providers (PAPs)
An Arkansas Medicaid enrolled and qualified provider who is
licensed to diagnose and treat a beneficiary may be designated as a Principal
Accountable Provider (PAP) within the Episodes of Care payment improvement
initiative. Individual providers may be designated as a PAP only by a
promulgated episode.
181.000
Incentives to Improve Care
Quality, Efficiency and Economy
A.
Definitions
1. An "episode" refers to a
defined bundle 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.
4. A "valid episode" is defined as any
episode that meets criteria for inclusion in a calculation of cost and quality
measures for which a PAP is accountable during a performance period.
5. An "invalid (excluded) episode" refers to
an episode in which the services or the patient do not meet standard criteria
for inclusion set by the definition of each episode type. (Refer to the
Episodes of Care Medicaid Manual for episode-specific criteria.)
6. An "incentive" can either be positive
(gain-share) or negative (risk-share).
B. Medicaid has established a payment
improvement initiative ("payment improvement program") to incentivize improved
care quality, efficiency and economy. The program uses Medicaid paid claims
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 of
Care.
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, encouraging
referrals to efficient and economic providers who furnish high-quality
care.
E. All medical assistance
provided in the delivery of care for an episode may be included in the
determination of an incentive under the payment improvement program.
F. Incentives may be positive (gain share) or
negative (risk share). Incentives are calculated and made retrospectively,
after care has been completed and reimbursed in accordance with the published
reimbursement methodology. Incentives 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 incentives and appropriate
quality measures based on evidence-based practices. To identify evidence-based
practices, Medicaid shall consider clinical practices information furnished by
Arkansas providers of the care and services typically rendered during the
episode of care, and may also consider input from quality measurement
organizations, 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.
Incentives
For each PAP for each applicable episode type:
1. Performance will be aggregated and
assessed over a specified period of time ("performance period"). For each PAP,
the average reimbursement across all valid episodes completed during the
performance period will be calculated, based on the set of services included in
the episode definition. Please refer to the Episodes of Care Medicaid Manual
for information about specific Episodes of Care.
2. Some episodes may be excluded based on
clinical factors derived from paid claims. Other exclusions may be determined
from coverage factors for each individual patient.
3. Reimbursement for some episodes may be
adjusted as described in the definition of each episode. The average adjusted
reimbursement of all episodes for the PAP during the performance period will be
compared to thresholds which are established by Medicaid in consultation with
providers.
4. If a PAP's average
adjusted episode reimbursement is lower than the commendable threshold and the
PAP has met the quality measures established by Medicaid for each episode type,
the PAP is eligible for gain share and Medicaid will make a positive incentive
to the PAP. This 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
an incentive calculated as though their average adjusted episode reimbursement
were equal to the gain-sharing limit.
5. If the average adjusted episode
reimbursement is higher than the acceptable threshold, the PAP will incur a
negative (risk-share) incentive. This incentive 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 or low cost
episodes and/or comorbid conditions so that one or a few cases do not
misrepresent a provider's overall performance across the provider's broader
patient population.
L.
Provider-Level Adjustments
1. 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 adjustments minus total negative
adjustments) for all Episodes 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.
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 manual(s), but are subject to positive (gain-share) and negative
(risk-share) 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. Each episode has a designated minimum case
volume that must be reached in order for the PAP to be eligible for incentives.
PAPs who do not meet the minimum case volume for an episode type will not be
eligible for positive (gain-share) or negative (risk-share) incentives for that
episode type.
M. Quality
Measures
1. For each episode type, there is a
set of quality measures "to pass" and/or a set of quality measures "to track."
These quality measures are based on paid claims data or based on additional
data when specified by Medicaid and which PAPs are required to report through
the Advanced Health Information Network (AHIN) provider portal.
2. To qualify for positive (gain-share)
incentives, PAPs must report required data and meet specific quality measures
"to pass."
3. Providers who do not
report data or who do not meet minimum quality measures may still incur
negative (risk-share) incentives 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.