Alternative Payment Model Receives Positive Response From HHS Secretary
In a September 29, 2019, letter from HHS Secretary Alex Azar to the Physician-Focused Payment Model Technical Advisory Committee (PTAC), the Secretary responded affirmatively to implementation of ACEP’s Acute Unscheduled Care Model APM (AUCM). The Secretary’s letter said the following about the AUCM:
American College of Emergency Physicians
I appreciate the ideas submitted to the Physician-Focused Payment Model Technical Advisory Committee (PTAC) by the American College of Emergency Physicians (ACEP) in its Acute Unscheduled Care Model (AUCM): Enhancing Appropriate Admissions proposal. I recognize PTAC’s detailed and rigorous review of this proposed physician-focused payment model (PFPM), and the discussion of incentivizing improved quality associated with emergency department (ED) physicians and care coordination.
The AUCM is a creative proposal to address ED payment policy that focuses on the safe discharge of patients, follow-up care for 30 days post-ED visit, and hospitalizations or other avoidable post-ED visit events and their associated costs. We agree with PT AC that patients who visit the ED and are discharged home could benefit from the proposed model. Likewise, we recognize the opportunity to incentivize improved quality and decreased cost associated with ED discharge decisions and appreciate the proposal’s goal of enhancing an ED provider’s ability to be an effective patient navigator. We believe smooth transitions of care from the ED to the community are an important component of delivery system reform.
I agree with PTAC that ED providers can influence transitions of care from the hospital and serve as one critical link in broader efforts to deliver coordinated, value-based care. I am interested in exploring how the concepts in the AUCM model for care management by emergency physicians after an ED encounter could be incorporated into models under development at the Centers for Medicare & Medicaid Services (CMS) Center for Medicare and Medicaid Innovation (CMS Innovation Center). We have further discussed care transitions with ACEP, and I have asked the CMS Innovation Center to assess how key mechanisms of action in this model could operate as a component in a larger model dedicated to improving population health.
HHS is using every available lever to create innovative payment structures to move our healthcare system toward greater value by rewarding quality, innovation and improved health outcomes, and increase provider participation. I am encouraged by submitters like ACEP who continue to help drive transformative innovation in American health care toward a value-based delivery system.
As published in previous issues of this newsletter, salient features of the AUCM remain:
Initial inclusion of four presenting complaints – syncope, chest pain, abdominal pain, altered mental status – and future roll out of other presenting complaints.
Historic 30-day facility-based target price calculation anchored to the initial ED visit.
Ongoing facility-based target price calculation.
Reconciliation payments or penalties based on comparison to historic target price.
Waivers for currently unreimbursed services including transitional care, telemedicine, and home visits.
Patient safety safeguards.
The voluntary nature of the model.
As noted in the Secretary’s letter, CMMI will be looking for ways to incorporate key elements of the AUCM into larger models already under development. BSA Healthcare expects that CMMI will coordinate with ACEP in the process of translation of key components of the AUCM into a Medicare model.
The potential transformative effect of the AUCM on the practice of emergency medicine cannot be overstated. If successful Medicare implementation is achieved, the practice of emergency medicine will no longer be limited to the confines of the emergency department. Emergency physicians will be integrated into the post-ED care of patients, causing a potential tectonic shift in both the practice of emergency medicine and the role that emergency physicians play in the health care delivery system.