LeadingAge NY Comments on Value-Based Payment Alignment Paper

As reported in last week’s Intelligence, the Department of Health (DOH) released a “Draft Medicare Alignment Paper” proposing to integrate Medicare and Medicaid Value-Based Payment (VBP) efforts. The proposal would:

• incorporate Medicare payment reform models (e.g., bundled payments, accountable care) into the State’s Medicaid VBP efforts;
• include Medicare beneficiaries in the Medicaid VBP models implemented under the State’s VBP Roadmap (e.g., global payment, integrated primary care, bundled payments, and total care for a subpopulation);
• encourage Medicare Advantage plans to pay providers using Medicaid VBP models; and
• allow Montefiore Health System to establish the first Accountable Care Organization to assume full financial risk and health responsibility for its entire Medicaid and Medicare population.

In an Aug. 14th letter to State Medicaid Director Jason Helgerson, LeadingAge New York expressed support for the stated goals of reducing fragmentation, increasing consistency in payment models, and recognizing Medicare savings within the Roadmap’s VBP models. However, we expressed several concerns, including: (1) Long-Term and Post-Acute Care (LTPAC) provider readiness to take on VBP for both Medicaid and Medicare; (2) the need for LTPAC providers to realize shared Medicare savings; and (3) taking greater advantage of existing models such as Fully Integrated Duals Advantage (FIDA) plans and Programs for All-Inclusive Care for the Elderly (PACE) rather than creating new, untested models.    

The alignment proposals will continue to be refined with input from the DOH VBP Workgroup, the VBP Technical Design Subcommittee, and other stakeholders. The Alignment Paper is available for public comment through Aug. 31, 2015.  LeadingAge NY’s Task Force on Alternative Payment Arrangements is meeting this week to further evaluate the proposal, and we may be submitting additional input to the State. Members with additional concerns or recommendations may submit them to Dan Heim by Aug. 19th for consideration by our Task Force. Comments may be submitted directly to DOH via e-mail by 3 p.m. on Aug. 31, 2015.

Contact: Dan Heim, dheim@leadingageny.org, 518-867-8866