Tag: value based care

Medical group improves risk accuracy and closes care gaps

Healthcare providers are under greater pressure than ever before and are forced to manage various competing demands for their time and attention. As the transition to value-based care accelerates, so does the need to collaborate with health plans to ensure complete, accurate coding and documentation to inform better risk adjustment and for Primary Care Physicians (PCPs) to actively identify and close care gaps. Patients also want (and deserve) quality healthcare interactions that recognize their unique needs, conditions and circumstances.

Against this backdrop, a lot is riding on the annual patient visit. Amid packed schedules, PCPs need to assess risk, address HEDIS gaps and ensure their patient is properly heard and cared for, with all questions answered and concerns addressed. 

At the same time, PCPs are chronically short on time and resources needed to complete required coding and documentation—often putting in two extra hours a day just to get through EMR backlogs. The continued rollout of CMS-HCC Model V28 will require even greater coding expertise and scrutiny, a troubling proposition for already-strapped providers who are facing burnout at alarming rates. 

Fortunately, by prioritizing and embracing accurate diagnosis coding—and drawing on expert partners like Vatica Health to help upskill PCPs and relieve the admin burden—providers can better identify and manage patient risks, close gaps in care, stay in compliance with evolving guidelines and, ultimately, thrive in a value-based care world. 

General Physician, PC, one of the largest and most respected medical groups serving Western New York and Northern Pennsylvania, has made it their mission to deliver quality care that’s second to none. Vatica partners with General Physician, PC to overcome the mounting complexity of risk adjustment and lessen the load associated with coding and documentation.

At the 2024 RISE Conference, Richard Charles, MD, Chief Medical Officer and Physician Lead for General Physician, PC, shared his group’s Vatica journey and the role accurate and complete coding and documentation play in helping close care gaps and deliver top-notch care. 

Dr. Charles’ PCPs—like many—needed support on the risk adjustment journey. Dr. Charles and Vatica knew they needed to shift the group’s perceptions that risk adjustment is a benefit only for health insurers and engage the team purposefully in striving for accurate coding and documentation. “There’s been considerable education of our providers around risk assessment,” says Dr. Charles. 

As providers continue to evolve their approaches and protocols in the name of value-based care, continued coaching and education around the upsides of improved risk adjustment—fair and accurate compensation, greater continuity of care, more proactive and higher-quality interactions and more—will separate the leaders from the pack.


“There’s been considerable education of our providers around risk assessment.” 


— Richard Charles, MD, Chief Medical Officer and Physician Lead, General Physician, PC

Vatica provides clinical teams plus user-friendly technology at the point of care to enable PCPs at General Physician, PC to capture more accurate and complete diagnostic codes, which helps optimize risk adjustment and leads to accurate CMS reimbursement. A prospective program not only benefits health plans—it helps providers proactively manage care with a comprehensive pre-visit workup of all active and suspect conditions aggregated from various sources. 

Curating only validated conditions and codes prior to the encounter, Vatica empowers PCPs to address HEDIS gaps through necessary interventions, like screenings or medication adherence, and make the most of their time with patients. “That pre-visit summary gets our providers thinking about not just the conditions but what care management is needed,” Dr. Charles explains. “It helps our providers build trust with patients.” 

Vatica also provides group training, one-on-one education and CME courses to help PCPs and their teams understand and overcome the complexities of coding and capitalize on the benefits of better risk adjustment. 

Dr. Charles cites a 10% improvement in risk score accuracy since General Physician, PC partnered with Vatica. He also found specific improvements in hemoglobin A1C levels and blood pressure control, attributed in part to Vatica’s process. “There’s a tremendous improvement in how many HEDIS gaps and how many other care gaps we’ve closed,” he says. 

“There’s a tremendous improvement in how many HEDIS gaps and how many other care gaps we’ve closed.” 

— Richard Charles, MD, Chief Medical Officer and Physician Lead, General Physician, PC


Figure 1: YoY Performance 2021–2023


General Physician, PC has capitalized on improved risk adjustment by using the newly captured revenue to offer additional services. These services give physicians valuable resources to help patients address issues and more time to focus on other clinical tasks and priorities. “We have a large clinical pharmacy program that addresses polypharmacy, high-risk drugs, transition of care, diabetes. We have nutrition, behavioral health, all of which are funded from these dollars,” explains Dr. Charles. “When a patient hears about all the services you have, they become more engaged.”


“We have a large clinical pharmacy program…nutrition, behavioral health, all of which are funded from these dollars.” 

— Dr. Richard Charles, Chief Medical Officer and Physician Lead, General Physician, PC

Accurate and complete coding benefits the provider, the practice and the patient. With Vatica as part of its risk adjustment protocol and clinic ecosystem, General Physician, PC has reduced the administrative burden on its team and optimized its diagnosis coding practices. And for Dr. Charles, that goes well beyond time savings or even compliance: “We want to take great care of these conditions, not just document that [patients] have them,” he concludes. 

What’s behind the move from retrospective to prospective risk adjustment?

Health plans across the country are recognizing the superior value of prospective risk adjustment programs, and rightfully so. These programs have impact at the point of care, as opposed to retrospective programs which are essentially chart reviews. Prospective risk adjustment programs permit timely, effective interventions. This includes presentation of suspected gaps in care and the opportunity to achieve thorough and accurate documentation, which supports coding to the highest degree of specificity.

Conversely, backward-looking retrospective risk adjustment programs limit effectiveness of code capture. A risk adjustment program consisting only of retrospective chart reviews is myopic and does not support the outcomes-driven, population health management focus inherent in most payment models today.

Which one is the optimal approach to risk adjustment? The answer: an effective mix of both. But most important is primary care physician (PCP) engagement. A winning risk adjustment strategy is heavily weighted towards prospective interventions but may need to include some retrospective elements to meet PCPs’ needs.

Prospective programs, while more operationally complex to deliver, are preferred because the ability to impact behavior at the point of care is powerful. It has significant cascading effects, including higher overall value, return on investment and reduced compliance risk. When coupled with PCP engagement, prospective risk adjustment can be the most effective method for obtaining comprehensive insight into the disease burden of a population. Prospective risk adjustment also enables forecasting the cost of care for your Medicare Advantage, Medicaid and commercial lines of business.

PCP engagement is the key to success across all risk adjustment strategies, especially prospective programs. PCP engagement improves care delivery and closes gaps in care by leveraging a proactive approach providing timely clinical and administrative support, education and performance management.

Ideally, health plans and physicians would collaborate to reduce costs and improve health, quality and outcomes. Additionally, members would self-advocate and proactively schedule preventive and wellness visits. Unfortunately, true engagement among all stakeholders in the healthcare continuum is rare and difficult to attain. Physician engagement requires timely, ongoing support. It is essential to augment practices with dedicated clinical resources who curate information to save the physician time by streamlining coding and surfacing gaps in care that require consideration during the encounter.

Furthermore, support staff who provide insights on performance and drive physician engagement are critical. Successful programs supply expertly trained people, easy-to-use technology, turnkey processes and aligned financial incentives to achieve and maintain physician engagement.

Lastly, member engagement is an important piece of the puzzle. Physicians are more likely to engage in programs that drive material clinical improvements for their patients, such as improved outcomes and quality of life.

Vatica Health is a compliance-first organization that enables a physician-centric approach to risk adjustment and clinical quality. We pair expert clinical teams with cutting-edge technology to work with physicians at the point of care. Vatica Health synthesizes EMR and health plan data to create the most comprehensive and complete view of each patient. We provide comprehensive PCP training as well as 100% clinical coding validation. All unsubstantiated codes are deleted prior to submission of the Vatica record to the health plan sponsor.

Our licensed registered nurses and administrative staff are dedicated to providing the best experience for PCPs and their office staff. Our attention to documentation and coding validation through Vatica’s quality improvement process improves accuracy and reduces compliance risk. Vatica’s clinical and administrative staff work closely with each practice to develop a custom workflow and process, achieving an ideal state that yields the best results with the least amount of effort for PCPs.

When health plans partner with Vatica Health, they ensure a comprehensive, collaborative and prospective risk adjustment program that’s a win-win for everyone, including patients. To learn more, visit vaticahealth.com.

Another blow to detached health risk assessments

By Brian Flower, vice president of client solutions, Vatica Health

Health Affairs recently published a study of data from 4 million Medicare Advantage (MA) members indicating that health risk assessments (HRAs) contributed up to $12 billion per year to risk adjusted payments in 2020. This is based on conditions that were submitted exclusively by an HRA (not submitted through another encounter) during the 2019 calendar year. The study implies that HRAs, typically performed in-home by vendors on behalf of MA plans, can lead to inflated hierarchical condition category (HCC) scores. More specifically, of the 44.4% of MA beneficiaries who had an HRA, HCC scores increased on average 12.8%.   

Study authors go a step further by segmenting contracts as low, medium and high, based on the HRA’s effect on risk score at the contract level. This may provide insights into HRA program design by the plan, e.g., which patients are targeted and how HRA outcomes are subsequently attached to care management.   

For nearly a decade, the Centers for Medicare and Medicaid Services (CMS) and the Office of the Inspector General (OIG) have expressed concern with the improper use of HRAs to inflate payments, rather than to improve care and outcomes. While HRAs can be a helpful tool for plans to identify all active conditions on an annual basis, the disconnect or “detachment” arises when diagnoses captured in HRAs are not recorded in a subsequent medical visit. This undermines the purpose of risk adjustment, which is designed to compensate plans based on the expected costs of delivering benefits to enrollees.    

Key observations 

  • The population was designated as follows: 20% low, 15% high and the remaining 64% in the medium cohort. 
  • While comprising only 15% of enrollees, the high cohort accounts for 48% of the total HRA risk-score increase. 
  • The HRA rate was much higher in the high contracts (77.9%) than low contracts (39.5%). 
  • Quality ratings favored low cohort contracts with 85% 4 stars or better vs high cohort contracts at 56%.  
  • Provider and health system integration was dramatically higher in the low vs the high contract cohort.   
  • Comparing the high and low contract cohorts, while the overall HCC score was 18% higher, medical expense was 9% lower (estimating from the plan payment and medical loss ratio values provided). 

Extrapolating on the points above, PCP-integrated risk adjustment solutions drastically reduce the risk of detached HRA outcomes and quality performance. This stands to reason because the patient’s PCP is prioritizing healthcare outcomes and management of chronic conditions, rather than focusing exclusively on code capture.     

The correlation between HRAs and coding intensity is particularly relevant given the Risk Adjustment Data Validation (RADV) Final Rule, which authorizes CMS to extrapolate RADV audit findings beginning with payment year 2018, applying the error rate from a sample, and the associated financial penalties, across a broader population of the Medicare Advantage Organization’s contract. In a RADV audit, conditions supported by a single encounter, like detached HRA visits, are at higher risk because there are no additional medical records to fall back on if there is an access, accuracy, or completeness issue with the primary record.  A PCP-integrated approach encourages follow-up care and additional documentation to support valid diagnoses.   

It should be noted that this study uses the 2020 CMS risk adjustment model.  We expect the exclusive impact of HRAs on risk scores would be tempered by as much as 40% using the 2024 risk adjustment model, which is being phased in now and will take full effect for 2025 dates of service. 

Conclusion  

At-risk entities should evaluate their current risk adjustment programs and focus on solutions that produce accurate and compliant coding accuracy that dovetail with quality and health outcomes. Legacy programs, such as retrospective chart reviews and HRAs completed by in-home assessment vendors, should be augmented with a provider-centric approach. Build a risk adjustment strategy that recognizes PCPs as partners in accuracy and quality capture, as well. PCPs are best positioned to capture all existing conditions and to address the CMS and OIG’s concerns by connecting the dots between accurate HCC capture and improved care and outcomes. 

Five ways you can begin addressing SDOH to improve outcomes and lower costs

It’s an inescapable fact: The lower a person’s socioeconomic position, the worse their health. Research by the World Health Organization (WHO)  has shown that non-medical factors—such as education, employment, food insecurity and housing—have a significant impact on the health disparity between rich and poor. In fact, it is estimated that up to 89% of the factors that  influence health exist outside of medical care. These factors are known as Social Determinants of Health (SDOH).

Government agencies and healthcare providers alike understand the impact of SDOH and want to do something to close the gap. However, a 2022 survey showed that while 80% of care providers believe that addressing SDOH is essential to improving health outcomes and decreasing costs, 61% said they lacked the time and the ability to affect the SDOH of their patients.

If, like the care providers surveyed, you’re committed to addressing SDOH but feel ill-equipped to make a difference in the near term, read on to begin making progress against your SDOH goals.

Below are a few tactics to consider, which are more fully described in a recent white paper, “Five ways you can begin addressing SDOH to improve outcomes and lower costs.”

Identify people in need and collect the data

Social screening needs to be a component of every patient visit. Screening tools, available through some EMRs and other sources, can help identify people in need within your patient population.

Master the codes

To ensure your clinicians and coders are up to date on the new Z codes, consider designating one staff member as your in-house SDOH expert and charge that person with following, disseminating and training colleagues on that information as it is updated.

Leverage payer resources

Health plans are also offering more direct SDOH support. For example, Anthem’s Member Connect program guides Medicare Advantage members to community health workers who help them find the community resources they need. This has increased healthcare engagement for 74% of members, resulting in an 8% reduction in hospital admissions and a 43% reduction in ER visits.

Build relationships with community resources

To drive better outcomes, it’s vital to connect patients to governmental and community resources that can help address their SDOH issues.

While referring patients to the appropriate programs is a good start, it is not enough; you should follow up to ensure they’ve made those connections. For that reason, it’s to everyone’s benefit for you to get to know and partner with community-based organizations (CBOs) to share information, ideas and issues and ensure referrals are followed up.

Emulate the successful methods of other care providers

The experiences of other providers may offer valuable lessons on what works and what doesn’t. For example, the University of Pennsylvania Health System discovered that offering patients a complimentary ride to an appointment did not lower patients’ 36% no-show rate. However, NorthPoint Health & Wellness Center  of Minneapolis  has seen success over the past 15 years by providing patients with bus tokens and hosting lunches with religious leaders of underserved communities. These and other actions have enabled NorthPoint to more than double vaccination and health screening rates to nearly 80%.

Addressing SDOH makes an impact

Taking proactive measures as described here will inform better decision-making and drive policies that work to undo the inequities in healthcare and lower costs for everyone. And when you build on those findings, using analytics to identify at-risk or in-need individuals, you can take the next step with outreach efforts that refer patients to relevant professionals and community resources.

Vatica Health can help. Our PCP-centric risk adjustment and quality of care solution combines technology with clinical consultants who review and curate all relevant health plan and EMR data. This results in a pre-visit notification that can help your team efficiently perform the visit, document patients’ health status and assist with care gap closure.

Interested in a more in-depth look at SDOH resources? Click here.

Advancing health equity with an index

By Jamie Jenkins, PhD, MBA, CPHQ, quality of care director, Vatica Health

Advancing health equity is the first pillar of Centers of the Medicare and Medicaid Services’ (CMS) strategic plan. The Biden-Harris administration has committed to promoting racial equity through government programs focused on underserved communities. To that end, CMS’ 2023 Medicare Advantage Quality Rule released in April 2023 finalized the new Health Equity Index (HEI) for measuring how well Medicare Advantage and Part D plans manage at-risk populations.

What is the index?

The HEI will drive health plans to fully engage and take steps to address the social determinants of health (SDOH) which negatively impact health quality and outcomes.

CMS has defined HEI as an index or single score that encapsulates contract performance for plans whose enrollees face specific social risk factors. The index will use existing data to limit the number of members who are identified as vulnerable. Stratified plan members who receive a low-income subsidy, those with a disability and those who are dual eligible will be in the scoring pool. Health plans should begin analyzing their data and designing programs to support these members.

What are the goals?

The initial goal of HEI is to increase transparency and understanding of plan performance in addressing the needs of members facing social risks. First, the index will be used to identify populations with the greatest needs so that targeted assistance may be granted to communities and providers serving those communities.

Second, the HEI will allow beneficiaries to select plans based on performance on health equity measures. Third, the index would become part of the Star Ratings program which is used to incentivize health plans with bonuses to improve performance. Prior to this new approach, there were no targeted incentives to address disparities among a plan’s enrollees. The HEI would be an added layer encouraging investment in health equity initiatives for Part C and Part D Star Ratings.

Call to action

Health plans have time to begin examining their approaches. The baseline data for the initial calculation of the HEI will be based on calendar years 2024 and 2025. The performance reward will be included in the 2027 Star ratings year.

Health plans can start their data analysis by comparing contracts to one another. For example, plans may consider the variances between those populations receiving a low-income subsidy versus those who are not. Comparing groups will allow plans to determine where support is most needed.

Data collection is key

One of the five priorities outlined by CMS in the framework is expanding the collection and analysis of standardized reporting. The agency seeks comprehensive, interoperable and standardized individual-level demographic and SDOH data. With an increased understanding of members’ needs, CMS plans to leverage quality improvement and other tools to ensure all members have access to equitable care and coverage.  

CMS notes that developments in health information technology have improved the ability to collect health data and measure disparities at the provider level. Vatica Health, for example, provides technology and dedicated clinicians to enable providers to efficiently capture more accurate and complete diagnostic coding and documentation both for risk adjustment and improving quality of care. Vatica’s team of nurses curates relevant clinical data from various sources and creates a pre-encounter provider notification to enable more comprehensive encounters. The notification lists medical conditions, unreconciled medications and targeted quality measures to help the provider efficiently address the patient’s needs during the visit. As part of this process, Vatica can collect race and ethnicity information as well, using CDC specifications.

In summary, this framework is the first step in CMS’ drive toward improving health equity. “Our goals for Medicare Advantage mirror our vision for CMS’ programs as a whole, which is to advance health equity; drive comprehensive, person-centered care; and promote affordability and the sustainability of the Medicare program,” said CMS Administrator Chiquita Brooks-LaSure.

How Vatica Health can help

If you are considering a partner to help improve your Star quality measure performance, consider Vatica Health. We are the #1 rated risk adjustment and quality of care solution for health plans and health systems. By pairing expert clinical teams with cutting edge technology, Vatica increases patient engagement and wellness, improves coding accuracy and completeness, identifies and facilitates the closure of care gaps and enhances communication and collaboration between providers and health plans. The company’s unique solution helps providers, health plans and patients achieve better outcomes together.

A wave of CMS regulatory changes – a new paradigm for risk adjustment

By Steve Zuckerman, cofounder and chief strategy officer, Vatica Health

Over the last several months there have been dramatic regulatory changes that will have a significant impact on Medicare Advantage Organizations (MAOs). The Centers for Medicare and Medicaid Services (CMS) made sweeping changes to both the audit process and underlying risk adjustment model, based on concerns with coding of conditions that the government claims are not credible predictors of future expenditures. These changes are against the backdrop of a wave of lawsuits and reports by the Office of Inspector General (OIG), alleging billions in overpayments emanating from legacy risk adjustment models such as chart reviews and home assessments.

Risk adjustment is the foundation of Medicare Advantage (MA). It’s a necessary but complicated process that ensures at-risk entities have sufficient funding to provide the appropriate care and resources to members based on their clinical profiles. As membership in MAOs has steadily increased over the last decade, so have the costs, leading to recent reforms. The first blow occurred on January 30, 2023, when CMS released the final rule on Risk Adjustment Data Validation (RADV Final Rule). This rule authorizes CMS to extrapolate RADV audit findings across a health plan’s entire membership base. The practical effect is that audits will be more frequent, and the new extrapolation methodology will likely result in much more significant fines and penalties (CMS estimates it will collect $4.7 billion more from plans over the next 10 years).  

The government’s next initiative to address coding errors and variations occurred on March 31, 2023, when CMS released the Calendar Year 2024 MA Capitation Rates and Part C and Part D Payment Policies (Final Rate Notice), which shifts diagnosis coding from ICD-9 to ICD-10 and removes over 2,000 codes from the Hierarchical Condition Categories (HCC) model. Despite a massive industry-wide lobbying effort from both payers and providers, the new risk adjustment model was adopted. However, CMS did agree to a phased-in approach over three years which represents a meaningful concession.

Finally, on March 27, 2023, a bipartisan senate bill was introduced by Sens. Bill Cassidy, R-Louisiana, and Jeff Merkley, D-Oregon, entitled the “No Unreasonable Payments, Coding or Diagnoses for the Elderly Act.” This bill seeks to exclude diagnoses from chart reviews and health risk assessments in the calculations of a patient’s risk score. While the bill is in the early stages of consideration, it is consistent with the prevailing perspective and momentum away from legacy models and toward involving treating providers in the risk adjustment process.

The phased-in approach under the Final Rate Notice gives MAOs an important opportunity to review their risk adjustment solutions to make sure they will be effective under the new regulatory landscape. Here are a few practical strategies to consider:

  1. Provider-centricity will be more critical than ever. As we transition to value-based care, it is critical for payers and primary care physicians (PCPs) to work together to improve care, outcomes and costs. Accurate risk adjustment is essential to ensure appropriate care for MA patients, the fastest growing healthcare segment. Therefore, it stands to reason that payers and providers should collaborate on risk adjustment and quality initiatives. Further, given the loss of several valuable HCCs under the Final Rate Notice, it will be more important than ever to ensure the capture and clinical substantiation of all risk adjustable conditions. Legacy models are deficient, work around providers, disrupt continuity of care and don’t accompany patient care plans. A better approach is to empower the PCP with tools and resources to perform HCC coding because the PCP has an existing relationship with the patient, direct knowledge of the patient’s history, and real-time access to the patient’s medical records. Enhanced payer and provider collaboration in this regard can produce better clinical and financial performance.

  2. Reevaluate chart reviews and home assessments. Chart reviews and home assessments that lack connectivity to the PCP and don’t impact care are being targeted by the Department of Justice, CMS and OIG. Both may become obsolete if the “No Upcode Bill” is ultimately passed. Lack of clinical oversight and perverse incentives within these legacy risk adjustment models create an environment ripe for error and malfeasance. Another major concern is that they are not coordinated with treating providers and therefore have minimal impact on improving overall population health and value-based care performance. Consider ways to coordinate your chart review and home assessment programs with in-office solutions to keep PCPs at the center of care.

  3. Focus on accuracy. In light of the RADV Final Rule and the myriad of lawsuits and investigations, at-risk entities should invest in solutions that produce compliant yield. They should focus on improving accuracy and completeness of documentation and coding and include a QI process that reviews both additions and deletions to validate coding prior to submission. The shift to value-based care will put even more pressure on payers and providers to use compliance-centric solutions that are focused on improving the accuracy and completeness of diagnoses codes and documentation.

How Vatica Health can help

Vatica Health is the #1 rated risk adjustment and quality of care solution for health plans and health systems. By pairing expert clinical teams with cutting-edge technology, Vatica increases patient engagement and wellness, improves coding accuracy and completeness, identifies and facilitates the closure of care gaps, and enhances communication and collaboration between providers and health plans. The company’s unique provider-centric solution is used prospectively at the point of care, giving the provider control and ensuring continuity of care. The solution helps providers, health plans and patients achieve better outcomes, together. Vatica Health is trusted by many of the leading health plans and thousands of providers nationwide. For more information, visit vaticahealth.com.

Elevating risk adjustment by activating physician participation

As the pandemic subsides, many PCP groups are seeking to restart or ramp up value-based care (VBC) initiatives that took a back seat to battling COVID for the past two years. The economic impact of COVID on PCPs heavily reliant on fee for service and the looming recession will only accelerate the transition to VBC. However, it does come at a time when many providers are short-staffed and feeling overwhelmed.

A recently-released three-year study by JAMA revealed that, between the fall of 2019 and early 2022, the percentage of healthcare workers who perceived emotional exhaustion in their workplace climate increased from 53.3% to 64.9%. The unfortunate reality is that many physicians are struggling with burnout which has been greatly exacerbated by the multi-year COVID crisis. Addressing this challenge requires collaboration and coordination of efforts among payers and providers.

How can care providers and payers work together to activate physician participation in this climate to improve diagnosis coding and documentation, close gaps in care, achieve better clinical and financial performance, and support VBC initiatives? Some answers were offered in a “Bright Spots in Healthcare” podcast.

Moderated by host Eric Glazer, the podcast offered the perspectives of a diverse, blue-ribbon panel of experts:

  • Jeslie Jacob, divisional vice president, provider analytics, reporting and connectivity, Blue Cross and Blue Shield of Illinois
  • Janie Reddy, DNP, FNP-BC, director of family medicine, CommuniCare Health Centers
  • Rebecca Welling, associate vice president, risk adjustment and coding, SelectHealth
  • Lisa Wigfield, RN, BSN, CCM, CRC, CDEO, clinical advisor, risk management, Priority Health
  • Hassan Rifaat, MD, CEO of Vatica Health

Watch the whole podcast to get the full story, but in the meantime, here are some key pieces of advice from the panel:

“The key is to bring the gaps in patient care into the workflow at the point of care.”

Successful VBC is built on data and analytics, but as Jeslie Jacob stressed, gaps in care must be visible at the clinician’s fingertips when interacting with the patient. Jacob emphasized the value of EMR integration and dashboards to ensure that clinicians have ready access to up-to-the-minute insights when they meet with patients.

“Capture as much as you can during the visit.”

Janie Reddy emphasized maximizing the opportunities presented by the office visit. “If a patient comes in for an acute visit – say, for a cough – we treat the cough, but we’re also looking to see if they’ve had their preventive screenings,” she said. “If they’re diabetic, have they had their A1Cs done for the year? We’re looking at the whole picture: all their quality metrics. It’s all embedded in data analytics and presented via dashboards that show us exactly what is outstanding for each patient.”

“It’s got to be documented to capture it.”

Data goes both ways, according to Lisa Wigfield. You’re not just using historical health data to inform the office visit; you’re also generating new, vital data during the visit. For that reason, she cited the importance of documenting everything, thoroughly and accurately. Wigfield mentioned how Priority has enhanced MA benefits and offers a “free to talk” visit that has no copay. The visit provides an opportunity for PCP and patient to talk about health. It’s a good way to address care gaps and discover new issues the PCP may not be aware of.

“Go from a physician-only approach to a team approach.”

Reddy is a firm believer in sharing the VBC workload among physicians and other staff so that the burden doesn’t fall disproportionately on physicians. There are several advantages to this. For one thing, it enables physicians to accomplish more during the time they have with patients. Secondly, it builds a sense of VBC ownership across the entire team. When everyone feels that they are being supported by their colleagues in making VBC work, the effort will be more sustainable. However, keep in mind that a successful team approach requires that each team member has a clear understanding of their role and responsibilities and the practice’s expectations of them.

“Make sure health plan incentive dollars flow down to the practice.”

Incentive dollars aren’t much of an incentive if the people earning them don’t receive them. That’s why Hassan Rifaat, MD, stressed that clinicians should be paid directly for the work they’re doing. He urges practices to “make sure money is flowing down into the practice, from providers to support staff; invest the time to figure out how to do that.” That tangible ROI for the team’s VBC efforts will help ensure their continued commitment. Dr. Rifaat also made a key point about the economics of VBC implementation: “The upfront costs of a VBC program are significant and it can take as long as two years for some of those investments to start generating positive cash flow,” he said. “Once it does, it’s self-funding. But until that happens, some form of subsidy can help providers make the investments needed to get their VBC program off the ground.”

“Be sure to include staff in the incentives.”

When it comes time to share incentives with staff members, PCPs have any number of ways to do it. Which is best? Rebecca Welling believes one effective way is to link specific incentive payments to the successful performance of specific tasks. “For example,” said Rebecca, “you could offer to pay your scheduling staff $25 for every one of these high-acuity patients they bring in.” The direct connection between task and reward can be a strong incentive.

“Take advantage of friendly competition.”

Don’t be reluctant to share provider performance data within your organization to spur friendly competition. Reddy said, “As clinicians, we have a competitive drive within ourselves, and this has really motivated us to push each other to deliver quality care to our patients.” Bottom line? Money isn’t the only incentive; competition can be a powerful tool, as well. To encourage competition, Dr. Reddy said “Dashboards are our friend.” Readily accessible and easy-to-read dashboards make it simple for physicians to compare their work with their peers’.

How Vatica Health can help

The Vatica Health solution directly supports many of the recommendations made by the experts on the podcast. Vatica Health is the leading PCP-centric risk adjustment and quality-of-care solution for health plans and health systems. By pairing expert clinical teams with cutting-edge, Vatica increases patient engagement and wellness, improves coding accuracy and completeness, identifies and closes gaps in care, and enhances communication and collaboration between providers and health plans. The company’s unique solution helps providers, health plans and patients achieve better outcomes, together. With the Vatica team providing the extra resources needed to get VBC off the ground and operating successfully, physician participation is easier to enlist and sustain. To learn more, visit https://vaticahealth.com/.

3 major PCP risks in VBC—and how to reduce them

By Lindsay Dosen, senior vice president of legal and compliance, Vatica Health

As more physician groups move into value-based care (VBC), many are encountering risk adjustment compliance issues they aren’t prepared for. Some of these issues can have serious legal and financial consequences if left unchecked. Preparing for these issues will enable physician practices to successfully transition to, and thrive in, a VBC environment by reducing compliance risk, improving patient outcomes and boosting financial performance. This article focuses on three common VBC compliance risks that PCPs should be aware of—along with recommendations on how best to mitigate them.

Risk 1: Unsubstantiated HCC codes

With the traditional fee-for-service payment models that PCPs have historically operated under, health plans—not PCPs—have primarily focused on accurately capturing Hierarchical Condition Category (HCC) codes for purposes of risk adjustment. However, under VBC arrangements (depending on the type of gain-sharing relationship), PCPs must focus on accurately capturing and documenting HCC codes. Underreporting or missing codes could translate to lost revenue for the PCP. Overreporting or submitting HCC codes that are inaccurate or unsubstantiated could subject the PCP to legal liability and regulatory penalties.

While this has been a major issue for health plans in recent years, this is also becoming a significant compliance risk for PCPs, as regulatory agencies have increased scrutiny of the risk adjustment programs and activities of both health plans and healthcare providers. These regulatory actions often assert violations of the False Claims Act (FCA) based on the government’s position that the risk adjustment payments were artificially inflated due to inaccurate or unsubstantiated diagnoses codes. Violations of the FCA can result in multi-million-dollar fines, not to mention lasting damage to a physician group’s public image and reputation, even when the violations were committed in error and without intentional wrongdoing by the PCP.

Fortunately, there are ways PCPs can protect against this compliance risk. First, PCPs should avoid payment structures that base payment on either a higher number of codes or higher-value codes. These types of payment arrangements are construed by the Department of Justice (DOJ) as problematic because they incentivize over coding and upcoding. Second, PCPs should provide training that reinforces the importance of compliant and accurate coding and that educates their staff about the potential legal, regulatory and financial risks associated with submitting inaccurate or unsubstantiated codes. Last, PCPs should invest in compliance programs that review coding and documentation to ensure accuracy.

Risk 2: Improper medical record review and sign-off

Another common VBC compliance issue that PCPs face is medical record compliance. You would think that the Centers for Medicare and Medicaid Services (CMS) recommended medical record review and sign-off process would be simple and straightforward. And it is—but only if the right person is doing it.

CMS outlines specific requirements as it relates to medical record documentation and risk adjustment diagnosis codes. Submissions with documentation issues could impact the validity of the medical record in a Risk Adjustment Data Validation (RADV) audit, leading to a potential discrepancy for the audited CMS-HCC findings. For a diagnosis to be risk adjustment-eligible, it must result from a face-to-face encounter with an approved provider type. The medical record must have, among other things, a valid signature and credentials for the approved provider. For PCPs, that means not just anyone in the practice can sign off on a medical record. A CMS risk adjustment-approved physician must be present during the face-to-face encounter. The record must also be signed by the CMS risk adjustment-approved provider. Learn more here.

This is an issue that can be easily remedied with proper education and training. PCPs should take steps to make sure that their staff clearly understands the importance of following the CMS guidance related to medical record documentation for risk adjustment. PCPs and their teams should read and be familiar with these compliance guidelines and should develop and implement policies and procedures to ensure compliance.

Risk 3: Vendor non-compliance

A third VBC issue is the misconception that a PCP’s responsibility for compliance is limited to only activities within the practice. If a PCP is working with an outside vendor that is non-compliant, the PCP may also be held liable for the vendor’s compliance violations.

The best way to mitigate this risk is to vet prospective vendors thoroughly in advance to ensure they have a clean compliance record and a strong compliance program in place. When selecting a risk adjustment vendor, PCPs should conduct due diligence to include, without limitation, reviewing information about the vendor’s compliance and security programs, any applicable coding policies and procedures, mechanisms for reporting suspected fraud, waste and abuse, exclusion screening, and any prior enforcement or legal actions taken against the vendor. In addition, a thorough review should be completed of the vendor’s operations related to the services being provided, including coding. Finally, PCPs should be thoughtful when structuring any fee arrangements with the vendor so as not to encourage over coding or upcoding. Payments under the arrangement should be based on the scope and quality of the services performed, without fluctuation (including bonuses or penalties) tied to the value or volume of the diagnosis codes captured.  

Final recommendation: appoint a compliance lead

These three issues are examples of the compliance risks that PCPs operating in VBC are faced with every day. However, they are also examples of how an effective compliance program can help PCPs successfully navigate these issues and substantially reduce risk in VBC arrangements. An important way to ensure the PCP has an effective compliance program is to appoint a compliance lead for the practice. The compliance lead should stay up to date on compliance requirements and guidelines, develop policies and procedures to ensure compliance, provide training, promote awareness, and monitor and enforce compliance within the organization. An effective compliance program, led by a person with knowledge and expertise related to the compliance risks and regulatory requirements that are applicable to VBC, can greatly mitigate the compliance and financial risks to the practice. With compliance adequately addressed, PCPs can focus on delivering efficient, high-quality care to patients, which leads to successful financial performance in a VBC arrangement.

Physicians want resources to address SDOH: Here’s where to find them

Physicians are well aware of the impact created by social determinants of health (SDOH) and want to address these needs, as indicated in a recent survey. But many believe they can’t help their patients, due to:

  • Limited time to discuss SDOH during patient visits
  • Insufficient staff to direct patients to the appropriate resources
  • Existing payer requirements that take time
  • Lack of reimbursement for screening for SDOH
  • Unavailable, inadequate or difficult-to-access resources

The good news is that as the focus on SDOH grows, more resources than ever are available to help physicians, from community resources to health plan-sponsored programs to time-saving solutions.

Primary care physicians (PCPs) can take advantage of multiple resources from their health plans. In particular, Medicare Advantage plans are rapidly transitioning to value-based care, at the direction of CMS. As CMS moves to pay for quality rather quantity, the depth and breadth of payer-sponsored programs grows.

SDOH programs show measurable improvements

Anthem, for example, offers the Members Connect program to its Medicare Advantage members. The program addresses social isolation and loneliness to improve members’ overall health. It connects members to a community health worker who helps them find specific community resources they need. Volunteers act as social care partners or “phone pals” who call members weekly to check on them and provide a social connection.

The program gets accolades from members: 74 percent said they increased engagement in their health. Anthem’s claims data shows that participants reduced hospital admissions by 8 percent and ER visits by 43 percent.

Superior HealthPlan, based in Texas, offers a multitude of programs: housing assistance, an in-house network of community health workers to guide members, and a unique program that helps provide funding for hygiene closets. The plan partners with community organizations across the state to offer these hygiene closets with products needed to maintain a healthy, active life. At nearly all of the hygiene closets, specific dates are designated as “Superior Days,” where plan representatives join with other community partners to host events and provide direct resources for those who need them.

To learn about programs available to their patients, physicians and office managers can contact their health plans’ provider representatives or quality teams.

Time-saving solutions

Lack of time and insufficient staff to address SDOH were cited by survey respondents as well. Here, too, PCPs can look to their health plans. With the transition to value-based care, plans offer resources such as care managers who support patients with SDOH-related needs. PCPs should be aware of which health plans offer these services and refer patients for additional support.

Note that ICD-10-CM Z codes are available to report patients’ SDOH but are generally underutilized by PCPs. When PCPs use these codes to report SDOH, that information is passed to health plans through claims. Plans can use that information to enroll patients into their various SDOH programs, alleviating the burden for PCPs.

Likewise, as plans ask PCPs to document and code Medicare Advantage patients’ health status for accurate risk adjustment, they may offer additional resources to assist patients with identified needs. A number of national and regional plans partner with outside resources, such as Vatica Health. Vatica offers a PCP-centric risk adjustment and quality of care solution, which combines technology and clinical consultants at no cost to the practice. These specially trained clinicians serve as an extension of the practice. They review and curate all relevant health plan and EMR data. This information is used to create a pre-visit notification to help the PCP efficiently perform the visit, document patients’ health status and assist with care gap closure.

Vatica’s time-saving solution enables PCPs to increase use of preventive services and improve patient satisfaction with Vatica’s combination of technology and clinical support teams. When patients’ conditions are accurately reported to health plans, that ensures adequate financial resources are available through CMS. This can also result in the patient receiving additional services from the health plan to address chronic care needs, complex conditions and SDOH.

More resources benefit PCPs and patients

SDOH continues to get more visibility, and rightfully so. This is good news for PCPs. More resources from health plans, government-funded programs and community organizations can help PCPs address SDOH. Outcomes include healthier, more satisfied patients and easy-to-access resources that can help to address lack of clinical staffing and staff burnout.

Bridging the quality gap through race and ethnicity reporting

As efforts continue to improve quality and reduce healthcare costs in the U.S., evidence shows that racial and ethnic health disparities have a significant negative impact. According to a report from the Commonwealth Fund, “Black and American Indian/Alaska Native (AIAN) people live fewer years, on average, than white people.” They are more likely to die from treatable conditions, to die during or after pregnancy and suffer serious pregnancy-related complications, and to lose children in infancy. Black and AIAN populations are also at higher risk for many chronic health conditions, ranging from diabetes to hypertension.  

The harsh reality of these health disparities was revealed by the COVID-19 pandemic and its disproportionate impact on people of color. Black, Hispanic and Asian populations in the U.S. have significantly higher infection rates, hospitalization, and death compared to white populations.  

The effect on the cost of healthcare is substantial. A recent Texas study showed that over the last six years, racial and ethnic health disparities in the state have resulted in $2.7 billion in excess medical spending and $5 billion in lost productivity.  

An important step to reducing disparities is efficiently collecting race and ethnicity data. This has proven to be a difficult task due to: 

  • The lack of standardized race and ethnicity categories 
  • Incomplete forms used to collect the data 
  • Electronic health records built without the ability to collect the information 
  • Discomfort of healthcare staff asking for information 
  • Few detailed descriptions for patients to accurately self-identify 
  • Patients may be reluctant to share this kind of information  

Additionally, social determinants of health (SDOH) have proven to be a significant source of disparity among racial and ethnic minorities. Using quality tools as a method for collecting data and advancing health equity has great potential to address the deeply rooted issues of SDOH. While some improvement has occurred, more work is needed.  

National Committee for Quality Assurance Strategies  

The National Committee for Quality Assurance (NCQA) compiles the Healthcare Effectiveness Data and Information Set (HEDIS). This provides quality results annually for more than 203 million people and 60 percent of the U.S. population. 

NCQA introduced a racial/diversity measure in 2015. But health plans struggled to obtain the needed data through member self-reporting, disease registries and other traditional means. NCQA’s 2019 records showed that approximately 76 percent of racial data and 94 percent of ethnicity data were incomplete for the commercial product line. Medicare plans demonstrated higher collection rates: 26 percent of racial data and 60 percent of ethnicity data is incomplete.  

The lack of completeness raised concerns about relying on traditional sources to accurately measure disparities in care. Without reliable data, identifying those with unmet needs is difficult. 

Improving Data Collection 

To increase collection of data from health plans, NCQA began requiring stratifications by race and ethnicity in 2021.  

NCQA started with five measures across key known disparities: colorectal cancer screening, controlling blood pressure, hemoglobin A1c control for patients with diabetes, prenatal and postpartum care, and child and adolescent well care visits.  

Race and ethnicity data on these measures help plans better understand member needs and provide services to address those needs. Plans can measure and track performance on disparities and implement data-driven approaches to close care gaps and improve outcomes in vulnerable communities, especially related to SDOH.  

Some plans are already working to close equity gaps. Centene Corporation was recently awarded the Innovation Award for Health Equity by NCQA. They implemented a data-driven approach focused on community disparities within markets. Improvements were seen in colorectal cancer screening rates for American Indian/Alaska Native members, increased rates of immunizations for Latino children and better maternal outcomes among Black mothers. 

Help is available to health plans seeking ways to reduce disparities of care among their membership. Vatica Health, for example, provides technology and dedicated clinicians to enable providers to efficiently capture more accurate and complete diagnostic coding and documentation for risk adjustment and improving quality of care. As part of this process, Vatica can collect race and ethnicity information using CDC specifications for the measures designated by NCQA. This helps Vatica clients meet NCQA requirements and collect the data needed to identify and reduce disparity gaps in care. 

Conclusion 

High quality, affordable healthcare for all isn’t possible without addressing disparities in our current system. Collecting race and ethnicity data is the first step toward developing effective solutions to address this complex challenge. While this is not a simple task, actions by NCQA and other stakeholders show potential. Collecting and using race and ethnicity data to identify disparities and factors that drive them is critical to achieving better healthcare for everyone. 

About Vatica Health  

Vatica Health deploys clinical nurses at the point of care, armed with powerful technology. Vatica’s solution accelerates the transformation to value-based care by helping providers, health plans, and patients work together to achieve better outcomes. Visit https://vaticahealth.com/ to learn more.