The HRSA Health Center Program and Medicare Site Enrollment NACHC Policy and Issues Forum March 29, 2019 Matt Kozar, Director, Strategic Initiatives and Planning Division Office of Policy and Program Development Bureau of Primary Health Care (BPHC) Health Resources and Services Administration (HRSA)
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The HRSA Health Center Program and Medicare Site …...FQHC Medicare Enrollment •Each health center site must separately enroll through Medicare to receive FQHC designation •To
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The HRSA Health Center Program and Medicare Site Enrollment
NACHC Policy and Issues Forum
March 29, 2019
Matt Kozar, Director, Strategic Initiatives and Planning DivisionOffice of Policy and Program DevelopmentBureau of Primary Health Care (BPHC)Health Resources and Services Administration (HRSA)
What is an FQHC?
FQHC
Health Center Program awardee
Health Center Program look‐alike
Entities that are outpatient health programs or facilities operated by a tribe or tribal organization under the Indian Self‐Determination Act or by an Indian organization receiving funds under Title V of
the Indian Health Care Improvement Act
HRSA
Medicare ‐ Social Security Act §1861(aa)(4) and Medicaid ‐ §1905(l)(2)(B) respectively define the “Federally Qualified Health Center” (FQHC) provider type.
2
FQHC Medicare Enrollment
• Each health center site must separately enroll through Medicare to receive FQHC designation
• To enroll, an entity must: Submit a complete application package (Form CMS‐855A and supporting
documents) to the appropriate Medicare Administrative Contractor (MAC) Receive from the appropriate CMS Regional Office a CMS Certification Number, a
signed Medicare agreement, and an effective date
3
Streamlining Medicare FQHC Site Enrollment for Health Centers (1/3)
• HRSA and CMS collaborating to streamline FQHC enrollment for health centers Since early 2017 CMS and HRSA have collaborated How can we share information that we both gather during our approval processes?
• Streamlining should lead to quicker approval of sites and provide health centers with the needed reimbursement to serve their patient populations
4
Streamlining Medicare FQHC Site Enrollment for Health Centers (2/3)
• HRSA will routinely provide CMS with health center site data to pre‐populate the Provider, Enrollment, Chain and Ownership System (PECOS)
• Health centers can upload supporting data into PECOS
• After health center validates information in PECOS, CMS will review and approve sites
• The goal is to reduce health center burden and incentivize health centers to use PECOS
• Health centers will also be able to validate currently enrolled site information in PECOS
5
Streamlining Medicare FQHC Site Enrollment for Health Centers (3/3)
• CMS plans to launch the system upgrade in PECOS in April 2019
• HRSA will conduct a webinar on April 24 with CMS to walk through the process
• Information will be forthcoming through the Primary Health Care Digest Register for the Digest:
Matt Kozar, Director, Strategic Initiatives and Planning DivisionOffice of Policy and Program DevelopmentBureau of Primary Health Care (BPHC)Health Resources and Services Administration (HRSA)
Medicare Fiscal Intermediaries calculated a per-diem rate for each FQHC
Divided total allowable costs by the number of total visits
Subject to productivity standards
FQHC Medicare Payment 1991 - 2014
Subject to a payment cap Rural (2013 – approx. $111)Urban (2013 – approx. $128)
Subject to annual reconciliation Increased annually based on the
Medicare Economic Index (MEI)
FQHC Medicare Payment –Affordable Care Act (ACA) 3/23/2010 - ACA signed into law, required the
development and implementation of a Medicare Prospective Payment System (PPS) for FQHCs
Initial PPS rate must equal 100% of the estimated amount of reasonable costs that would have occurred for the year if the PPS had not been implemented, without the application of copayments, per-visit limits, or productivity adjustments
FQHC Medicare PPS
1/1/2011 – FQHCs required to use HCPCS* coding on claims for use in the development of the PPS
Rate adjusted annually based on an FQHC Market Basket data
Current year (2019) - $169.77
FQHC Medicare PPS -Payment FQHC payment is the lesser of the FQHC’s
charge for the specific payment code or the PPS rate PPS rate is adjusted by the FQHC GAF
(geographic adjustment factor) FQHC payment is adjusted for new patient* visit,
AWV, or IPPE (34%)*A new patient is someone who has not received any Medicare-covered professional health service (medical or mental health) from any site within the FQHC organization, or from any practitioner within the FQHC organization, within the past 3 years from the date of service.
FQHC Medicare PPS –Payment Codes
G Codes required to bill for a FQHC visit(including Medicare Advantage plans)
G0466 – Primary care, new patientG0467 – Primary care, established patientG0468 - IPPE or AWVG0469 - Mental health, new patientG0470 - Mental health, est. patient
FQHC Medicare PPS –G Codes FQHCs set their charge for the specific payment
codes (G0466-G0470) based on their determination of what would be appropriate for the services normally provided and the population served, and the description of services associated with the payment code
The charge should reflect the sum of the regular rates charged for a typical bundle of services that would be furnished per diem to a Medicare beneficiary
CMS does not dictate to FQHCs how to set their charges
FQHC Medicare PPS –Claims
Must contain a G code (G0466-G0470), HCPCS code, and a revenue code
FQHC PPS Specific Payment Codes (https://www.cms.gov/Center/Provider-Type/Federally-Qualified-Health-Centers-FQHC-Center.html)
FQHC Billable Visits
Face-to-face (one-on-one) medically-necessary medical or mental health visit, or a qualified preventive health visit, between the patient and an FQHC practitioner during which time one or more FQHC services are rendered, and
Only services that require the skill level of the FQHC practitioner are considered FQHC billable visits
FQHC Medicare Payment
Payment includes all services and supplies furnished incident to the visit
One billable visit per day, except for subsequent illness/injury, mental health visit, or IPPE visit
Payment for Certain New Medicare Services Payment for certain new services
that do not meet the requirements for a stand-alone billable visit and are not included in or incident to a stand-alone billable visit
Payment for Certain New Medicare Services General Care Management
Services
Psychiatric Collaborative Care Management Services
Virtual Communication Services
Payment for Certain New Medicare Services
General Care Management Services CCM (Chronic Care Management) General BHI (Behavioral Health Integration)
General Care Management ServicesCPT 99490* (> 20 min. of CCM services directed
by an FQHC practitioner, per calendar month)CPT 99487* (> 60 min. of CCM services of
moderate to high complexity, directed by an FQHC practitioner, per calendar month)
CPT code 99491* (>30 min. of CCM services furnished by an FQHC practitioner, per calendar month)
CPT code 99484* (>20 min. of general BHI services, directed by an FQHC practitioner, per calendar month)
*FQHCs do not bill these codes
General Care Management - Payment Payment set at the average of the PFS national,
non-facility payment rate for the 4 codes 2019 Payment Rate - $67.03 per beneficiary
per month Must use G0511 on claim No waiver on coinsurance and deductibles Billed alone or with other payable services Payment rate updated annually based on the
PFS amounts for applicable codes
G0511 - Eligibility
CCM - 2 or more chronic conditions expected to last >12 months or until the death of the patient, and place the patient at significant risk of death, acute exacerbation or decompensation, or functional decline, or
General BHI - Any behavioral health or psychiatric condition being treated by the FQHC primary care practitioner, including substance use disorders, that, in the clinical judgment of the FQHC primary care practitioner, warrants BHI services
Occurring no more than one-year prior to commencing care management services
Furnished by a primary care physician, NP, PA, or CNM
G0511 Requirement -Consent Obtained by the FQHC practitioner or auxiliary
personnel before the provision of care management services
Written or verbal, documented in the medical record Includes information on the availability of care
coordination services and applicable cost-sharing, that only one practitioner can furnish and be paid for care coordination services during a calendar month, that the patient has the right to stop care coordination services at any time, effective at the end of the calendar month, and that the patient is giving permission to consult with relevant specialists
G0511 Requirement -Services Directed by the FQHC primary care
practitioner, who remains involved through ongoing oversight, management, collaboration and reassessment
Furnished by an FQHC practitioner or by clinical personnel under general supervision
Specific service requirements for CCM and for general BHI (see Chapter 13 of the Medicare Benefit Policy Manual)
CCM in FQHCs
Total Beneficiaries
Total Payment
Top 5 States
2016 2,532 293,352 NC, KY, CA, MA, GA
2017 11,403 1,654,549 CA, SC, NC, GA, AR
2018 31,527 6,738,984 CA, SC, NC, WV, NY
Payment for Certain New Medicare Services
Virtual Communication Services
Virtual Communication Services - Requirements
>5 minutes of communication technology-based or remote evaluation services are furnishedby an FQHC practitioner to a patient who has had an FQHC
billable visit within the previous year, AND
Virtual Communication Services - Requirements
The medical discussion or remote evaluation is for a condition not related to an FQHC service provided within the previous 7 days, and
The medical discussion or remote evaluation does not lead to an FQHC visit within the next 24 hours or at the soonest available appointment
Virtual Communication Services - Payment
Payment set at the average of the PFS national, non-facility payment rate for these 2 codes: HCPCS code G2012* (communication
evaluation services)* FQHCs do not bill these codes
Virtual Communication Services - Payment Effective 1/1/19 2019 Payment Rate - $13.69 per service No frequency limitations Must use G0071 on claim No waiver on coinsurance and deductibles Billed alone or with other payable services Payment rate updated annually based on
the PFS amounts for applicable codes
FQHC Medicare Payment Policies
Questions???
Medicare CCM for FQHCsIndiana Quality Improvement Network
March 29, 2019
Agenda
Introduction to the Indiana Quality Improvement Network
Transformation toward the Quadruple Aim
Health Center Challenges
Medicare CCM Opportunity
Lessons Learned
Who are we?• PCA‐Based Health Center Controlled Network
• 26 Participating Health Centers
• Governed by HCCN Committee of the PCA Board of Directors
One Network, Varied Capacity
A Unified Vision
Risk Stratification Age Ranges End Age # PatientsPediatric 21 34035Adult 65 50048Geriatric 7688
NACHC Value Transformation Framework: Risk Stratification Action Guide:http://www.nachc.org/wp‐content/uploads/2018/02/Action‐Guide_Pop‐Health_Risk‐Stratification‐Sept‐2017.pdfAAFP Risk Stratified Care Management Rubric:https://nf.aafp.org/Shop/practice‐transformation/risk‐stratified‐care‐mgmt‐rubric
Managing High Risk & High Cost Patients
Challenges
Medicare ACO
Health Home
Payments
Alternative Payment Models
Care Management
PMPM
Care Management
Staff
Health Center Grit
Opportunity Knocks
•Medicare CCM Billing Code G0511 available to FQHCs and Look‐Alikes•$62.28 PMPM for 20 Minutes of Care Management•Aligned with our desire to build sustainable care management capacity
Medicare Patients
• 8.2% Medicare• 41,600 Medicare Patients
• 7% High Risk• 21% Moderate Risk
• 200 patients x 6 months of CCM = $74,736
Our Population Health Approach
Great Lakes Practice Transformation Network Partnership
Recruited 10 Health Centers (5 GLPTN/5 IQIN)
Focus on Diabetics with at least one other Chronic Disease
Our Implementation Approach
Billing Training
Quality Improvement Model: Lean Daily Improvement
American College of Physicians Chronic Care Management Toolkit: What Practices Need to Do to Implement and Bill CCM Codes*
• 3 certified• 10 in progress• 5 waiting to launch
Processes
• ID eligible patients• Consent/enrollment• Educate providers and care teams
• Daily huddles
Tools
Electronic Health Record
• Generating Lists of Eligible Patients
• Chronic Care Management Modules
Azara DRVS
• Risk Stratification Registry
• Care Management Passport
• Cohorts to track improvement in HbA1c Control
• Care Manager
Other
• Practice Analytics• Spreadsheets
CCM Progress
Identify
• Pulling patient lists
• Internal processes
Enroll
• > 300 Patients• Documentation• When to call
Bill
• > 300 Patients• >550 Claims• >$40,000 charges
• <$1,000 paid
CCM Activities
Medication Reconciliation
•Medication refills
• Medication literacy
• Dosage changes
Behavioral Goals
• Diet• Physical Activity
• Self management
Care Coordination
• Referrals• Transitions of care
• ED visits discussions
SDOH
• Screening• Referrals• Employment
Success Stories
Social Determinants Solutions
Education for Self‐Management
Protecting Livelihoods
Barriers
Organizational Readiness
EHR limitations
Don’t want patients to have co‐pay burden
Indiana Medicaid not paying co‐pay for Dual‐eligible
Working through billing kinks
Contact
Angela BoyerHCCN Director, Indiana Quality Improvement [email protected]‐983‐1002Indiana Primary Health Care Association429 N. Pennsylvania St., Ste. 333Indianapolis, IN 46204