HPC: PCMHs, RPO, OPP, CHART and CMIRs (You Can Look It Up)
Hope you got your acronym cheat sheet handy.
The Health Policy Commission (HPC) met for its tenth full commission meeting on Wednesday November 20th. Several important issues were discussed at the meeting, including the patient center medical home (PCMH) certification, the Registered Provider Organization (RPO) program, the Office of Patient Protection (OPP) regulations, and several updates on cost trends and market performance including Cost and Market Impact Reviews (CMIRs). Follow along with the presentation deck for the meeting, and click on for our full report.
Medical Home and ACO Standards
Commissioner Carole Allen led the discussion on care delivery and payment system reform, specifically addressing PCMHs. Commissioner Allen addressed the overlap between PCMHs, Accountable Care Organizations (ACO), primary care, integrated care and specialty care (see slide 9-11). During her presentation, Commission Chairman Stuart Altman raised several concerns with fee for service payments to PCMHs. Commissioner David Cutler then suggested the Commission could make recommendations from the literature about how organizations should pay providers in PCMH or ACO settings but could not do anything on this issue in the area of regulation.
The next topic discussed was the registered provider organization program. Executive Director Seltz led the discussion on this topic, noting that the Commission was working closely with the appropriate regulatory bodies on RPOs. He then went on to describe the three aims of RPOs: to enhance transparency, to map the provider delivery system and to create a centralized resource for the Commonwealth and other stakeholders. He also described which provider organizations must register and the process by which they will be identified (see slide 16-17).
Next, Director of the Office of Patient Protection Jennifer Bosco presented the proposed OPP regulations. Ms. Bosco described the foundations of the proposed changes which include the Affordable Care Act (ACA), the Massachusetts ACA implementation law (Chapter 35 of the Acts of 2013), other MA laws (including Chapter 224) and the need to provide clarifications for consumers and stake holders. The regulations proposed include clarifying the grounds for filing grievances, faster resolution of internal grievances and external reviews, simultaneous review of claims by certain patients with urgent medical needs and consumer friendly fee changes. Also included were proposed changes to the internal and external review processes (see slides 23-25). Chairman Altman question whether the proposed rule that requires expedited member grievances and expedited external reviews to be resolved within 72 hours, (a decrease from the current rule of four days), was enough time. Ms. Bosco responded by stating that this new regulation is required by the ACA and that the shortened time period should not be an issue. The Commission then voted to approve the OPP proposed regulations.
Community Hospital Fund
Next up was a quick discussion on the Community Hospital Acceleration, Revitalization, and Transformation (CHART) investment program (formerly the Distressed Hospital Fund). Executive Director Seltz stated that the request for proposal (RFP) had been released for phase 1 and that the total amount of funding available for this phase is $10 million while the total amount that can be granted to an individual institution is $500,000. The deadline to apply is December 11th, 2013.
The final topic of discussion was on cost trends and market performance. Commissioner Cutler first led the discussion on the annual cost trends report and the all payer claims database (APCD). The purpose of the APCD is to support the annual cost trends report and create a foundation of the Commission’s work and the work of other APCD users. The next cost trends report is expected to be released in December. Commissioner Jean Yang then brought up the fact that drug prices are not looked at in these reports. Commissioner Allen responded by stating that drug data will be included next year. Commissioner Cutler then stated that the Commission will continue to evaluate what information and analysis is necessary to gather with the goal of deepening our understanding of the health care system and moving towards policy. He also reiterated that the findings from the cost trends analysis need to be turned into actionable steps.
Cost and Market Impact Reviews
The next topic of discussion was the material change notices. Karen Tseng, Policy Director for Market Performance at the Commission led the presentation on this topic. She discussed the statutory factors for review of material changes (see slide 37) and the categories and questions for impact reviews (see slide 38-39). She also presented the modeling quantitative analysis for Cost and Market Impact Reviews (CMIRs) (see slide 40) and the types of transactions they have noticed in 2013 (see slide 43). The most common type of transaction was physician group affiliation or acquisition. Ms. Tseng then laid out the timeframe for pending notices. They are as follows: the deadline to initiate any CMIR for the acquisition of Winchester Hospital by Lahey Health System is November 29th; for the acquisition of Hallmark Health Corporation by Partners HealthCare system is December 12th, and for the acquisition of Emerald Physician Services by Medical Affiliates of Cape Cod is December 18th. During the presentation, Commissioner Cutler commented that the Commission really wants to learn from their first CMIR and reevaluate the process by, for instance, asking institutions and organizations more specific questions. A major point of discussion amongst all the Commissioners was what would be the outcome of a CMIR. Would the Commission make a recommendation or just lay out the facts? What exactly will the Commission say in these reports? It was suggested that this be a major topic of discussion for the next Commission meeting.
The final topic of the meeting was an update on the Partners-South Shore CMIR. Ms. Tseng stated that the Commission staff had received most of the data and documents requested of the parties and other market participants; that they were in the final stages of their review and analysis of information provided; that they were continuing to meet with parties and market participants to discuss their work and that they were on track to complete a preliminary report by the end of the year. Ms. Tseng then stated that they had received formal notice of an important physician component within the broader Partners-South Shore alignment – the Partners acquisition of Harbor Medical Associates (slide 48). The Commission then voted to authorize the continuation of the CMIR of the proposed material changes to Partners and Harbor Medical Associates.
Following this vote, there was a short public comment period. Michael Caljouw of Blue Cross Blue Shield of Massachusetts spoke, as did a representative from the social work community. The next Commission meeting is scheduled for December 18th, 2013.