Independence at Home Demonstration Program
The Centers for Medicare and Medicaid Services (CMS) recently launched a new three year demonstration program designed to provide care to Medicare patients with chronic conditions the old fashioned way – in the home.
The Independence at Home (IAH) Demonstration Program was deployed through the Patient Protection and Affordable Care Act (PPACA March 2010) Section 3024 in late December 2011. The program will greatly expand the scope of in-home services for Medicare beneficiaries. Traditionally, many of these potential patients would have to be admitted to an institutional or more formal setting to receive care (hospital, skilled nursing facility). Under the IAH demonstration program they now may be eligible to receive a full comprehensive care plan right in their home.
IAH is another demonstration program released by CMS that is aligned with the quadruple aim of health care reform: Provide care in the most appropriate setting, improve outcomes, reduce cost and enhance the patient experience. It’s also an opportunity for practices to test whether in-home primary care can reduce hospitalizations, hospital readmissions and emergency department visits.
CMS goes on to say in its IAH Press Release that “CMS will join with medical practices to test the effectiveness of delivering primary care services in a home setting and improving care for Medicare beneficiaries with multiple chronic conditions. Medicare practices led by physicians or nurse practitioners will provide primary care home visits tailored to the needs of beneficiaries with multiple chronic conditions and functional limitations.”
Through the coordinated plan of care and interdisciplinary care team, CMS does expect a Minimum Savings Requirement (MSR) to be generated; similar to Medicare Shared Saving plans, Pioneer Accountable Care Organizations (ACO) and Bundled Payment models. The anticipated MSR will be calculated by CMS for each demonstration provider based on their listing of eligible Medicare beneficiaries. In addition to payments, incentive payments can be produced for programs that score successful outcomes based upon six defined quality measures.
To be eligible to participate in the Demonstration medical practices must include physicians and nurse practitioners that are familiar and experienced in providing home-based primary care services. Up to 50 practices will be selected for the demonstration and must be willing to serve at least 200 Medicare beneficiaries that fit the designed patient profile for the program. CMS is looking to register up to 10,000 Medicare beneficiaries. Unlike other shared savings programs, the practice will be responsible for identifying its eligible caseload and for certifying the eligibility of each applicable beneficiary. Eligible beneficiaries are defined as Medicare fee-for-service (FFS) patients who need assistance with at least two chronic conditions, two functional impairments, hospitalization in the past 12 months and use of rehabilitation or other post-acute care in the last 12 months.
Interested eligible medical practices will need to act quickly if you would like to participate in the Demonstration. Letters of Intent and Applications are due February 6, 2012.
An Eligible Practice is one that:
- Has experience in providing home-based primary care
- Makes in-home primary care visits
- Are available 24 hours a day, 7 days a week
- Is organized at least in part for the purpose of providing physician services
- Uses electronic health records, remote monitoring and mobile diagnostic technology
- Furnishes services to an average of 200 or more applicable beneficiaries during each year of the demonstration
- Reports information about their patients and the health care services provided
- Reports on required quality measures.
It is important to note that practices are limited to participating in only one shared savings initiative at a time. Therefore, if the practice is participating in an ACO or a Pioneer ACO, it would be prohibited from participating in the IAH Demonstration Program. Additionally, eligible beneficiaries to be included in the Demonstration must be entitled to Medicare part A and enrolled in Medicare part B, not enrolled in a Medicare Advantage plan or a Program for All-Inclusive Care for the Elderly.
Under the three year Demonstration IAH providers will continue to bill and be paid standard Medicare FFS reimbursement. Annual spending targets will be calculated by CMS for each participating practice at the end of each performance year. Savings will be calculated as the difference between each practice’s spending target and actual costs. The savings could then be shared with the practice in the form of an incentive payment if other participating conditions are achieved.
An eligible provider can participate in the IAH demonstration under three different options if they meet the eligibility criteria:
Option 1 – Any practice meeting the eligibility criteria may apply as a sole legal entity.
Option 2 – Multiple primary care practices within a geographic area may form a consortium in order to participate.
Option 3 – Practices with a beneficiary caseload ranging from 200 to 500 beneficiaries may choose to become a part of a national pool of providers. However, under this option, practices waive the right to have their savings evaluated as a single practice. Any distribution of savings through incentive payments would be based upon the savings of the entire national pool.
CMS defines one’s “home” as simple as “where the beneficiary resides.” The home can be, according to the Agency, a house, an apartment, an assisted living facility or any other non-institutional location. For the purpose of the demonstration, a nursing facility would not be considered a beneficiary’s home.
Please remember that the due date to file your Letter of Intent and Application with CMS is fast approaching – February 6, 2012. More information about the IAH Demonstration Program can be found on the CMS website, Federal Register / Vol. 76, No. 245 or you may contact your BNN advisor at 1.800.244.7444.
Disclaimer of Liability: This publication is intended to provide general information to our clients and friends. It does not constitute accounting, tax, investment, or legal advice; nor is it intended to convey a thorough treatment of the subject matter.