HPC Getting Set to Name Names?
On November 18th, the Health Policy Commission (HPC) Board met to discuss a number of new developments that relate to rising healthcare costs and quality improvement in the Commonwealth. The full slides from Wednesday’s presentations can be found here.
The meeting started with a presentation from Executive Director David Seltz summarizing recent activities at the HPC. Mr. Seltz outlined recent successes from the CHART Investment Program – a program to improve hospital outcomes through an aggressive series of awards, coaching, and technical assistance. This month, eight new awards were launched focusing on reducing emergency department reutilization.
Two Commission staffers introduced the payer and provider Performance Improvement Plans (PIP). A unique feature of the Massachusetts 2012 health care cost control law, PIPs provide a mechanism for the HPC to identify and respond to payers and providers who exceeded the state’s health care cost growth benchmark. For 2015, that benchmark is 3.6 percent. The Center for Health Information and Analysis (CHIA) has provided a confidential list of potential offenders to the HPC. HPC then will notify the identified entities and may require them to file a PIP to implement options to reduce cost growth such as investing in efficiency measures, changing prices or referral practices, and more. The HPC revealed that CHIA has already created this list based on data from September 2012 to September 2013 along with preliminary 2014 data and identified under twenty providers and under five payers who may have exceeded the cost growth benchmark.
Health and Human Services Secretary Marylou Sudders voiced concern that payers and providers would be automatically blacklisted if they went even “0.0001 percent” over the cost growth benchmark and urged the Commission to instead look at the trends and stories behind the numbers to determine their validity. Secretary Sudders also pointed out that certain factors out of payer and providers’ control, such as rising drug costs, could present a warped image of actual cost growth. Secretary Sudders also reiterated the importance of having regulatory guidance prior to notifying identified payers and providers. After a brief back and forth with Commissioner Stuart Altman who emphasized the need for transparency with the public, the Board agreed to an amended version of the process that included drafting regulatory guidance and conducting preliminary screening and analysis of payers and providers identified by CHIA.
Next, the board briefly discussed their criteria for Patient Centered Medical Homes based on national standards advanced by the National Committee for Quality Assurance. The hope is that strong standards will send a signal to patients that they can get the highest quality medical care by choosing a practice that meets the state's definition. After months of stakeholder design feedback, the HPC settled on behavioral health integration as their initial additional domain for PCMHs, going one step beyond the national PCMH standards. Of the thirteen preliminary criteria, PCMHs will have to meet at least seven to become certified by the state. The criteria were approved unanimously.
The final action item was another standards-related vote, on preliminary ACO certification criteria. After explaining the process used to develop the initial criteria and outlining the goals of the certification program, HPC staff discussed some of the common themes they encountered throughout their stakeholder engagement. Many agreed that there was a balance between being too prescriptive and allowing providers to innovate the best ways to improve care while lowering costs. At the same time, many stakeholders reiterated the importance of incorporating behavioral health and long term support services into ACO criteria. Notably missing was the inclusion of oral health or dental benefits. The full criteria will be released for public comment in January and hopefully finalized by February of next year.
Last on the agenda was a presentation from the Office of Patient Protection, who presented recent findings on internal and external appeals. Overall the data showed an apparent lack of patient education regarding their right to file external insurance appeals and the persistent discrepancy of mental and behavioral health services.
The next meeting of the Health Policy Commission Board will be held on December 16th, 2015.
-- Kate Frisher