April 30th, 2011 by StevenWilkinsMPH in Health Policy, Opinion
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Ok…here’s a brain teaser. What medical condition is the most costly to employers? I’ll give you a hint. It is also a medical condition that is likely to go unrecognized and undiagnosed by primary care physicians.
If you guessed depression you are correct. If you mentioned obesity you get a gold star since that comes in right behind depression for both criteria…at least in terms of cost and the undiagnosed part.
Four out of every ten people at work or sitting in the doctor’s waiting room suffer from moderate to severe depression. Prevalence rates for depression are highest among women and older patients with chronic conditions. Yet despite its high prevalence and costly nature, depression is significantly under-diagnosed (<50%) and under-treated by physicians.
For employers, the cost of depression cost far exceeds the direct costs associated with its diagnosis and treatment As the graphic above indicates, the cost of lost productivity for on the job depressed workers (Presenteeism) and lost time for depressed workers that are absent from the job (Absenteeism) far exceed the cost of cost of treatment (medical and medication cost).
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*This blog post was originally published at Mind The Gap*
April 20th, 2011 by Stanley Feld, M.D. in Health Policy, Opinion
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In 2009 President Obama stated that Accountable Care Organizations (ACOs) were going to be pilot programs in real world settings. The goal was to see if they effective in reducing costs and increasing “quality of care.” The results of the pilot programs have not been published.
Last week despite the lack of proof of concept HHS and CMS announced new proposed regulations for ACOs.
The new delivery and payment model the agency estimates could serve up to 5 million Medicare beneficiaries through participating providers, and also potentially save the Medicare program as much as $960 million over three years.
How were these estimates derived? It could be another accounting trick by President Obama’s administration.
The idea of coordinating care and developing systems of care is a great idea theoretically. From a practical standpoint, execution is very difficult.
I tried to execute something similar in 1996 with the American Association of Clinical Endocrinologists; a national Independent Practice Association. AACECare received little cooperation or interest from Clinical Endocrinologists.
The problem is coordinated medical care is dependent on physicians cooperating and not competing with each other. It also depends on hospital systems developing an equitable partnership with physicians.
The equitable partnerships between hospital systems and physicians are difficult to achieve if past results are any indication of future results. Read more »
*This blog post was originally published at Repairing the Healthcare System*
April 13th, 2011 by BobDoherty in Health Policy, Opinion, Primary Care Wednesdays
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When I talk to internal medicine audiences around the country about the latest health policy flavor of the day – accountable care organizations (ACOs) – a typical reaction is skepticism trending toward cynicism. Many don’t quite get what ACOs are all about and certainly don’t want to be lectured about how they need to re-invent their practices. And they don’t buy the idea that ACOs will somehow save internal medicine primary care. The same can be said, perhaps to a lesser extent, about their reactions to PCMHs (Patient-Centered Medical Homes), P4P ( pay-for-performance), HIT (health information technology), MU (meaningful use), and the whole alphabet soup of other reforms being proposed to reform health care delivery and payment systems.
And who can blame them? Older internists have seen this all before, and the word has gone out from them to medical students and younger doctors not to trust policy prescriptions that promise to save primary care. Read more »
*This blog post was originally published at The ACP Advocate Blog by Bob Doherty*
April 11th, 2011 by DavidHarlow in Health Policy
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ACO regulations and related federal issuances hit the street last Thursday, after several months of waiting — from CMS, OIG, FTC, DOJ and IRS. They cover the waterfront, ranging from the central regulation defining the structure and workings of the ACO, to limited Stark self-referral ban and anti-kickback statute waivers in the fraud and abuse arena, to new frameworks for antitrust analysis, to rules governing joint ventures involving taxable and tax-exempt organizations.
I had the opportunity to discuss the regs the day after they were issued on a special edition of the Blog Talk Radio show, ACO Watch, hosted by Gregg Masters (@2healthguru). Gregg’s guests included Mark Browne (@consultdoc), Vince Kuraitis (@VinceKuraitis), Jaan Sidorov (@DisMgtCareBlog) and yours truly (@healthblawg). We are geographically diverse, and bring a variety of perspectives to the table. I invite you have a listen — we enjoyed the opportunity to discuss the rules, we all learned from each other, and we hope you enjoy the conversation as well. (It runs about 90 minutes.)
Update 4/5/2011: For a collection of ACO analyses curated by Anita Samarth see: http://bit.ly/ACO-Analyses.
Here are a few points to consider as part of a first look at the ACO rules:
1. The rules were worth the wait. There are a lot of moving parts to coordinate, and the multi-agency effort really came together. The CMS rule also retains a fair amount of flexibility. Some requirements are very specific, but others much less so. (For one example of specific guidelines, take a look at the eight-part definition of patient-centeredness; an organization must satisfy all eight in order to be an ACO. Other requirements have no detail at all, and CMS will look to applicants to explain how they meet the requirements, without giving any hints.)
2. This is the Frankenstein regulation: A Medicare beneficiary must sit on the board of the ACO, CMS must approve all marketing materials before they are used …. These requirements may be traced back to origins in CMS demonstration project and Medicare Advantage policies, respectively, and illustrate the way in which CMS took a short statute and really put some meat on the bones. Some may balk at the weight of the requirements limiting the options of an ACO.
3. CMS has bootstrapped a law aimed at ACOs serving at least 5,000 Medicare beneficiaries each into a system of rules that effectively requires that commercial business be handled in an ACO-like manner. This, among other infrastructure requirements (e.g., 50% of ACO docs must be meaningful users of EHRs), leads to the conclusion that there will be relatively few ACOs, at least initially. CMS estimates 75-150 nationwide. There are, of course, many unanswered questions about what a commercial ACO would look like. One model I am familiar with — here in the People’s Republic of Massachusetts — is the AQC, or Alternative Quality Contract offered by Blue Cross Blue Shield of Massachusetts to providers enrolled in its HMO Blue product. One question is whether a slightly different financial model could apply to the commercial side of the house. One model worth a close look is Jeff Goldsmith’s proposed ACO model, which would treat primary care, emergency and diagnostic care, and episodes of specialty care in three distinct ways.
In brief, Goldsmith recommends risk-adjusted capitation payments for primary care, fee-for-service payments for emergency care and diagnostic physician visits, and bundled severity-adjusted payments for episodes of specialty care. Primary care would be provided through a patient-centered medical home model, which would likely have a collateral effect of reducing the total volume of emergency care and diagnostic physician visits. Specialty care would be provided through “specialty care marts,” ideally more than one per specialty per market to maintain a little healthy competition.
A quick explanation of this approach to an intensivist over the weekend elicited a favorable response.
4. Also in the bootstrapping department, CMS has shifted the ACO from a “shared savings” approach to having ACOs share risk as well as the upside. Of course, this makes a lot of sense; a number of commentators, including the HealthBlawger, had lamented the fact that risk sharing was left out of the statute. CMS has used its general waiver and demo authority under the ACA to move the ACO into risk sharing. The ACO may choose: share risk from day one, and enjoy a potentially higher percentage of the upside, or defer the risk sharing to year three.
5. The retrospective nature of patient attribution and savings calculations mean that each ACO must treat every Medicare fee-for-service patient as if he or she is “theirs.” Patients have the right to decide whether they want their data shared with an ACO; if enough patients are spooked by health care data privacy and security issues, fewer and fewer will authorize the sharing from CMS to the ACO, and the ACO will have to drive by feel — or base its management of Medicare beneficiaries on its management of its general patient population.
6. Organizations that dominate their local markets may be the most successful as ACOs, but they may face the most involved antitrust review at the hands of the FTC/DOJ.
7. Scoring on 65 quality metrics in 5 domains will help determine the amount of any shared savings to be paid to an ACO. One domain, patient experience of care, links up nicely with the patient-centeredness threshhold requirement noted above. (For private sector attention to patient experience, see what the Leapfrog Group is doing in this domain, using some of the same measures.) While some may bristle at the number of metrics, it is worth noting that these metrics are all drawn from existing sets of measures.
8. All in all, the regulations represent the first stage of realizing the ACO vision expressed by Don Berwick last fall: there is a field open to experimentation (albeit a field likely limited to large networks of significant means that can underwrite the up-front infrastructure costs), and the ACO rules sketched out in the statute and further delineated in the regulations will enable CMS to incentivize the provider community to help achieve the triple aim of better care for individuals, better health for populations and reduced per-capita costs.
David Harlow
The Harlow Group LLC
Health Care Law and Consulting
*This blog post was originally published at HealthBlawg :: David Harlow's Health Care Law Blog*
February 15th, 2011 by DavidHarlow in Health Policy, Research
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There’s a growing recognition within the medical-industrial complex that the patient is a key element of the enterprise, and that patient satisfaction, patient experience, patient engagement, patient activation, and patient-centeredness are very important. Some research shows that patient activation yields better patient outcomes, and that patient activation can be measured.
Patient-centeredness and patient engagement are two of the key metrics to be used by the feds in describing Accountable Care Organizations (ACOs), if the internecine battles within government are resolved soon enough to actually release draft ACO regulations in time to allow for sufficient advance planning for the January 2012 go-live date. (Wearing one of my many hats, I’ve had the opportunity to submit a response to CMS regarding the RFI on these metrics on behalf of the Society for Participatory Medicine.) These measures go into the “meaningful use” hopper as well, as meaningful use stage 2 metrics are being reviewed.
In recent years, the federales have been measuring patient experience using the Consumer Assessment of Healthcare Providers and Systems (CAHPS) surveys, and — coming soon to a bank account near you — there will be Medicare dollars tied to the scores on these questionnaires, not just dollars tied to the act of reporting scores.
As this emphasis on patient experience is unfolding, the Leapfrog Group is adding its voice to the chorus. I spoke this week with CEO Leah Binder and hospital survey director Matt Austin about the new patient experience measures they are adding to their 2011 hospital survey. In keeping with past practice, they will be asking hospitals to report three CAHPS measures (rather than asking folks to collect and report new measures). The three were selected as being representative of a hospital’s broader performance with respect to patient experience, and also because hospital performance on these measures is all over the map. Read more »
*This blog post was originally published at HealthBlawg :: David Harlow's Health Care Law Blog*
