NCP Guidelines: Domain 1 - Structure and Processes of Care
December 8, 2018
Ready or Not...Primary Palliative Care is Coming
August 2, 2016
Yesterday (August 1, 2016) CMS opened applications in 14 geographic regions for the Comprehensive Primary Care Plus, a "national advanced primary care medical home model that aims to strengthen primary care through a regionally-based multi-payer payment reform and care delivery transformation." At first glance this may seem like something hospice and palliative care providers can ignore, yet if you read closely, the patient population includes patients who often need and don't have access to palliative care. According to the Comprehensive Primary Care Plus FAQ practices opting to participate in Track 2 will have the opportunity to receive a higher monthly fee to care for high risk patients:
"What kind of patients will be included in the “complex tier” of top 10 percent HCC for the CPC+ care management fee? The top 10 percent of the HCC risk pool will represent patients who are the “sickest of the sick,” with multiple conditions and high expected costs. The exact range of HCC scores and number of beneficiaries assigned to the complex tier will vary based on region, due to different populations and variations in coding practices. For a more detailed description of the HCC methodology, as well as detailed information on what diagnoses are included in the HCC scores, please refer to this independent evaluation report. In addition to beneficiaries in the top 10 percent HCC, beneficiaries who have a diagnosis of dementia will also be assigned to the complex tier."
All the primary care practices selected to participate will deliver what CMS is calling the Five Primary Care Functions:
Access and Continuity
Planned Care for Population Health
Patient and Family Caregiver Engagement
Comprehensiveness and Coordination
I don't have to tell you that these functions are integral components of palliative care. Over time more and more primary care providers will receive incentives to care for high need, high cost patients in a cost-effective way.
Why You Should Care
As I've been saying for years, CMS is pushing, pulling, and prodding providers into value-based healthcare agreements. All the practices participating in Comprehensive Primary Care Plus will receive a risk-adjusted monthly care management fee. Practices in Track 1 will also continue regular fee-for-service billing. Track 2 practices will receive "a hybrid of fee-for-service and Comprehensive Primary Care Payment." The expectation is that practices will redesign their services to reduce unnecessary health care utilization for high risk patients. The more robust, non-visit-based compensation can be used to supplement staffing and training to enhance care coordination.
Across the country and in all care settings non-palliative care providers that are responsible for high-risk populations are already or will soon:
partner with palliative care programs OR
integrate palliative care-like services into their practices
Yesterday an oncologist told me that as many as 20% of their entire practice could benefit from palliative care. She was confident that all her colleagues would welcome the introduction of palliative care. She said the need for palliative care was significant because she and her colleagues are “unable to spend the time needed with patients whose disease is incurable to help them understand the limitations of their illness.” She told me this during a palliative care needs assessment interview I was conducting for a hospice client.
That's huge. She and her colleagues know they need help and see palliative care as a solution. Are there providers like that in your community?
Do you know which practices in your community are redesigning their practices to provide comprehensive care for seriously ill patients?
Have you looked at the Medicare data to see which specialists are responsible for high numbers of fee-for-service billing in each specialty?
Have you looked at the post-acute care data to what type of post-acute care services patients admitted to the hospital 2 years before death received? Do you know if those patients ever received hospice?
These are the types of questions you need to ask as you explore partnerships with physicians, hospitals, and payers to develop a community-based palliative care program.
The clock is ticking... it's time for palliative care providers to join forces with primary care practices, hospitals, and payers to meet the palliative care needs of seriously and chronically ill people. kb
Are you building a community-based palliative care program?