CMS's Star Ratings Firing Squad Gets Squirt Guns
Last week, in a surprise move, the Centers for Medicare and Medicaid Services (CMS) reversed its threat to terminate all Medicare Advantage and Part D health plans with 3 or fewer Stars for more than 3 consecutive years. Roughly a dozen health plans were lined up in front of the firing squad as an example to the industry for months -- and then CMS issued squirt guns to the executioners.
It's a one-year stay of execution, with the one year of course being an election year. Importantly, CMS said it will terminate contracts if plans do not achieve at least a 3-star rating by 2016. Our favorite agency maintains the authority to deny applications submitted by poor performers, and to deny an application if it has terminated an MA or PDP contract within the past 38 months. There is a 14 month "grace period" for new plans to comply.
CMS Medicare Chief Sean Cavanaugh made the surprise announcement (beginning at 20:30 on the YouTube video) Thursday along with a September 8 policy letter that went to a handful of media outlets, but strangely isn't posted on the CMS website or communicated to Medicare plans via the Health Plan Management System. The memo noted:
"In delaying the terminations of these low performing contracts, CMS expects all contracts that have for at least three years received...a Rating of less than 3 stars to concentrate on improving the quality of care provided to their enrollees. These contracts must focus on the overall health care needs of their individual enrollees, including improving enrollee experiences and ensuring that their enrollees receive needed clinical care. These efforts should improve CAHPS, HEDIS, HOS, patient safety, and adherence scores. Organizations and sponsors should focus on all areas where the contract has received less than 3 stars. Organizations and sponsors must take into account their enrollee populations and target any interventions to improve quality to the specific needs of their enrollees. In many cases, a one-size-fits-all approach for interventions will not work.
"CMS may be following up with contracts designated as having a low performing icon (LPI) to discuss their performance and will determine whether enforcement or compliance measures other than contract termination pursuant to §§ 422.510(a)(4)(xi) and 423.509(a)(4)(x) should be utilized to ensure that the contract comes into compliance with CMS' requirements."
Barclay's eminent analyst Josh Raskin pointed out that "WellCare is the biggest beneficiary of this change with 9.5% of its total Medicare Advantage members enrolled in plans with consistently (i.e., three consecutive years) less than 3-stars." Raskin looked at how publicly-traded Medicare Advantage plans' 2.5 and 2.0 star enrollment trended over the past two years. He concluded over 200,000 Medicare Advantage lives are at risk when the stay of execution is over next year. "Among the companies with the greatest risk, Centene is most exposed, with roughly 19% of its membership in plans below three stars, followed by Universal American with 16% and WellCare with roughly 12% of its membership in plans below three stars," he said.
On the positive side, Raskin noted Humana continues to makes strides with the company's "at risk" enrollment declining from roughly 550K lives in 2011 to 25K last year, and that Molina has also made progress, improving the rating of its sole 2.5-star plan above the 3.0-star threshold last year. All of UnitedHealth's sub 3-star plans increased to a 3-star plan last year, leaving the company with very little "high risk" enrollment.
So, we'll have to wait another year for a public hanging in Star Ratings Square. But all of this serves as further evidence of what a game-changer Star Ratings have become in government programs, from the crappy consumer information tool they were just 4 years ago.
Resources
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Why Medicare ACOs Were Always a Bad Deal, and Why They Need an Exit Strategy
Last week, the tenth of 32 Medicare Pioneer ACOs dropped out of the program. Others are expressing reservations about entering or continuing given the experience of Pioneers and the hundreds participating in the Medicare Shared Savings Program (MSSP). To be clear, it's not all bad news...but most ACOs will need an exit strategy, fast.
Medicare ACOs were never a fair deal. As I pointed out last week, the problem with the Pioneers, and in fact with all Medicare ACOs, is that the rules tilt the playing field toward CMS, often to the detriment of the ACO. Most significantly, the downside risk, as required by CMS, is irrational. Any ACO incurs substantial downside risk in the form of its investments to participate and its operating costs.
A rational deal would be: the ACO incurs operating costs, and it gets a share of any savings it generates. The risk is that savings are not enough to cover costs. Your reward is that you keep any excess over operating costs, although CMS couldn't resist putting a ceiling on that, too. Adding a financial penalty if costs exceed the benchmark doubles down on the downside, giving the ACO two ways to lose money, and only one way to make money — by generating savings in excess of costs. Losses incur a penalty, in addition to operating costs. Small gains still leave a loss if operating costs are not covered -- so only large savings offer a profit. This is not a fair deal, especially for ACOs in already-efficient markets like Sharp in San Diego.
In the CMS math, the "losses" that incur downside risk, and require refunds to CMS, result from per capita costs for Part A and B services for assigned beneficiaries exceeding a benchmark. The benchmark is supposed to represent the per capita cost for these bennies if the ACO did nothing. Costs below the benchmark represent the degree to which the ACO has succeeded in doing something effective.
I can think of only two scenarios in which costs would exceed this benchmark cost of doing nothing. One is collusion by the ACO providers to increase Medicare billings. That is illegal, and already carries stiff penalties, and nobody would try it in a public demonstration. That leaves only one other explanation: the benchmark is supposed to represent the per capita costs if the ACO does nothing. If the ACO does something and still incurs a loss, that means that the benchmark is defective. CMS does a poor job of incorporating risk adjustment into the benchmark, and, as in the case of Sharp, the benchmark is not necessarily adjusted year to year at a rate that reflects local market changes. That means the downside risk imposed by CMS is really a penalty for its inability to get the benchmark right. That is not a fair deal.
In addition to the problems with the downside risk requirement, even if you do generate large savings, your share of those savings will be reduced unless you achieve near perfection on 33 quality metrics selected by CMS. The ink is barely dry on the first set of metrics, and CMS is already proposing to change half of them. When one party to a deal keeps shifting the goal posts, it is not a fair deal.
So as we see it, as many as three-quarters of Medicare ACOs need an exit strategy, and fast. Many Medicare ACOs' 3-year demos will wrap up in 2015-2016, so as early as next year dozens will look at the significant investments in time and treasure and nonexistent ROI and say, "what's next?" They have three major choices:
- Go back to traditional fee-for-service Medicare with a hole in their budget and scars on their asses. Pursue commercial ACO arrangements that are attractive, and effectively flush the investment in Medicare management down the toilet.
- Enter, or go deeper into, contracts with one or more Medicare Advantage plans in the market, leveraging infrastructure and experience into a channel where money can be made and quality rewarded. Most MA plans recognize that a Medicare ACO with a record of savings and quality is primed to be a good risk partner.
- Build your own Medicare Advantage plan and move up the food chain. A successful Medicare ACO has already mastered the hardest parts of eldercare: care management and an engaged network of high-performing providers. What's missing is insurance functions, which can be built or bought.
Those Medicare ACOs that choose the latter path have good reason to do so: Medicare Advantage remains a sound investment opportunity in most markets for 5 big reasons:
- Beginning in 2017, the MA benchmark is guaranteed to grow at the same rate as FFS Medicare, whereas the Medicare ACO benchmark resets every 3 years, confiscating most hope of shared savings.
- Medicare ACOs have to be good diagnostic coders to avoid losing revenue, whereas in MA that's an enormous financial advantage under risk adjustment.
- ACOs share their savings with CMS; MA plans keep theirs. Boom.
- Medicare ACOs with demonstrated quality watch CMS keep less of what they've already earned, while quality gets MA plans a bonus -- and new entrants automatically start with a 3.5 Star Rating and a 3.5% bonus.
- Medicare ACO beneficiaries are "free range". There is no lock-in and the same level of benefits for any Medicare provider. The MA benefit design is a lock-in that favors in-network utilization. Free range is only tastier when referring to carnivorous treats, not capitalist ones.
Those Medicare ACOs that choose the latter option need to move fast. To evolve into a Medicare Advantage plan, a Medicare ACO needs to have confirmed its market's financial viability, and then build or arrange for:
- state licensure and financial reserves, and must hold 100% of risk net of reinsurance;
- a highly developed function to manage Federal and state regulatory requirements;
- a sophisticated and accountable sales and marketing structure;
- transaction processing like eligibility, enrollment and claims;
- a member-centric member service operation.
These capabilities can be homegrown, obtained from the health plan down the street or from third-party vendors like TMG Health, or some combination thereof. But either path takes time, and sound health plans aren't built during a fire drill. A Notice of Intent must be submitted to CMS in November and application made in February for the following contract year -- so at this point you're talking 2016 entry at the earliest, 2017 most likely.
If you're a health system watching this all unfold, let me suggest this: instead of investing in a Medicare ACO, take your money to Vegas or to Medicare Advantage -- in either place you know the rules and the odds.
Resources
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The Medicare ACO Demos Are a Mess. Here's What it Means for Health Plans.
This week, another Medicare Pioneer Accountable Care Organization Demonstration site, longtime GHG client Sharp Healthcare in San Diego announced it was dropping out. It was the tenth Pioneer to quit the trail, and not for lack of trying. Many of the Pioneers did great on improving quality and reducing costs -- the issue is not the performance of Pioneers. It's CMS' methodology, with its requirement for Pioneers to bear risk in the third year, and benchmarks calculated to make any gainsharing impossible.
The deck was stacked against them from the beginning, including inability to control beneficiary out-migration, inability to generate meaningful savings if the network was already highly efficient, and the beneficiary at-will opt-out. It's left dozens of Medicare ACOs in both Pioneer and the more than 330 in the Medicare Shared Savings Program (MSSP) scratching their heads and wondering how to monetize the millions they've invested in population health and complex case management -- the "hard part" of Medicare managed care.
I think many will conclude it's time to move up the food chain and become Medicare Advantage plans, and we'll start seeing them next year, with a mini-surge to follow in 2016 and 2017. Look at it this way: Even if only 10% of all Medicare ACOs decide to jump into the elder insurance game, we could be talking as many as 40 new Medicare Advantage plans entering the program over the next three years. All of them local and/or regional powerhouses with loyal followings to command those thousands of "assigned" beneficiaries. At a minimum, a Medicare Advantage contract of their own would command big leverage in negotiations with competing plans they may already be in business with.
To participate in Pioneer or MSSP, health systems needed to develop sophisticated reporting structures to meet CMS demands, as well as the significant investments needed to better manage their elderly frequent flyers. They assembled more integrated, coordinated providers and held them to tough quality standards, and for the most part, they delivered. But for all the hard work of evolving their delivery systems, most -- we estimate as many as three-quarters -- won't see a penny from either demonstration.
Many of these ACOs will look at the health plans they contract with in Medicare Advantage, flip the model on its head, engage the plan or a vendor like TMG Health to operate "back office" insurance functions like enrollment, and enter the market in 2016 or 2017 as private-label senior plans.
They'll have a great story to tell, loyal followings, brand recognition, and -- hugely -- will enter Medicare Advantage with the newbie default 3.5 Star Rating, including the 3.5% bonus. And let's not forget 2016 and 2017 are when the worst is over in the Medicare Advantage rate cuts from the Affordable Care Act, with MA benchmarks being pegged at the traditional Medicare growth rate. These two factors, not to mention a health system's inherent advantage in collecting risk adjustment diagnostic codes, should provide a substantial tailwind to these new entrants. Disappointed Medicare ACOs will reinvent themselves as MA plans making an entrance in 2016-2017 like Beyoncé at the Video Music Awards.
This mini-surge of provider-sponsored MA plans should be considered by many sectors of our industry, from provider relations execs and health plan strategists, to pharmacy benefit managers and other vendors hunting new prospects. Disruptive events like the Affordable Care Act have ripple effects, and one will be the evolution of ACOs into full-risk insurers seeking to control their own destiny. And we need to look no further than members of the Health Plan Alliance, systems like Geisinger Health Plan, or UPMC, or Security Health Plan to see the impact they can make.
If you're a Medicare Advantage Plan with a Medicare ACO in your neighborhood, or worse in your network, start sleeping with one eye open. It's now time to keep your friends close and your enemies closer.
Resources
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Health Plan Strategists: Fish Where the Fishes Is -- in LTSS
One of the best pieces of advice I ever got in business was to "fish where the fishes is", and for health plan strategists it holds up. In this Golden Age of Government-sponsored Health Programs, one of the biggest fishing holes is Long-Term Services and Supports, and a new primer from KFF lays out the opportunity beautifully. And the hazards: patients who require LTSS are of course the most vulnerable and complex patients in the entire US health system, literally the final frontier for health plans and coordinated care. Huge risk, huge rewards.
LTSS -- often totally unfamiliar to both Medicare and Medicaid plans, and requiring new types of providers in-network -- help the elderly and disabled with activities of daily living, and include nursing home care, adult day care, transportation, and caregiver supports. As a nation in 2012 we spent $368 billion on LTSS, 40% of that from Medicaid, and 20% from Medicare, and likely to be around $400 billion today. That's way more than what we're spending on ObamaCare's exchanges and subsidies on an annual basis. It's unsustainable already, and is now a top-2 item in most state budgets. And with seniors 85+ now the fastest-growing segment of the US population, and their needing LTSS at four times the rate of their younger cohorts, the urgency to convert these vulnerable patients to a coordinated care environment has never been greater, and it's happening fast.
Most LTSS reforms occurring at the state level involve transitioning frail elders and the disabled from the human warehouses of nursing homes and rehab hospitals to home and community-based settings, often under a capitated financial arrangement. With a year of nursing home care costing $90,000+ but a home health aide or adult day care running about $20,000, it's not hard to see why 45 cash-strapped states are pushing this transition.
The catch is that with the complexity of these populations, and the growing resistance of beneficiary advocates, especially for the developmentally disabled, this transition will involve an unprecedented degree of transparency and accountability from health plans. If you think Medicare Advantage Star Ratings measures are tough, you ain't seen nothin' yet. Many quality standards for the frail and disabled, like provider visit timeliness and drug adherence, haven't even gotten off the drawing board yet, and they often vary by state. What's clear is that service and coordination expectations of regulators will be far more robust for very old and disabled beneficiaries. That means more emphasis on data-driven case management and coordination, in-home and in-community interventions, robust reporting for regulators and actionable clinical intelligence for providers.
So strategists should "fish where the fishes is" and plan to participate in these groundbreaking programs -- but come equipped.
Resources
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American Action Network Promotes Government Subsidies
The American Action Network (AAN), a 501(c)(4) conservative think tank, has published a report that purports to show that Medicare Advantage (MA) payments will be about 13% less in 2015 than they would have been had the Affordable Care Act not interfered. To get the attention of members of Congress, the report shows the reductions by Congressional district.
The AAN analysis doesn't mention sequestration, which probably accounts for 2% of this 13%. Sequestration of course, has nothing to do with the ACA. Nor do they mention MedPAC's repeated recommendations to Congress to reduce the benchmarks that determine MA payments, so that they equal Medicare's average fee for service (FFS) costs. For example, see MedPAC reports in the period just prior to the passage of the ACA: http://www.medpac.gov/chapters/Jun09_Ch07.pdf and http://www.medpac.gov/documents/Mar10_EntireReport.pdf.
Reducing Medicare Advantage payments to parity with Medicare FFS, as recommended by MedPAC, is the reason for the cuts that the ACA imposes. As usual in Washington, the word "cuts" in this context doesn't mean an absolute reduction, just less than what would have been spent under the old law.
The AAN report does not describe how either the projected 2015 payments or the pre-ACA 2015 payments-that-would-have-been were calculated, so there's no way to comment on the validity of the 13% figure beyond the above observations. By my calculations, the ACA reductions amount to about 9% less than what the average benchmark would have been, before sequestration. With sequestration, I come up with a reduction of 11% relative to the trended pre-ACA benchmark, compared with the AAN's 13%. That figure doesn't take into account any changes in risk adjustment or quality bonuses, which the AAN report claims to include. One would expect risk adjustment to be a net positive, even after the increase in the amount deducted by the coding intensity adjustment, as plans have gotten better at coding. And quality bonuses are also a net positive, even with the end of the Stars demo in 2015. So adding these to the 9% reduction in the published benchmark should produce a smaller reduction, relative to the pre-ACA benchmarks trended forward. So I am skeptical of the 13% figure published by the AAN, without more information regarding how they calculated the 2015 pre and post ACA figures.
However, it is worth noting a couple of consequences of the pre-ACA figures. One is that these additional payments would have been funded, in part, by an increase in all Part B premiums, including those paid by non-MA members. Avoiding this increase is tantamount to a tax cut for Medicare beneficiaries. Yet the conservative AAN, whom I would expect to applaud anything that has the effect of a tax cut, is criticizing this reduction.
The other consequence is that the remainder of the additional payments would have been drawn from public funds. These funds would come either from the Part A trust fund, or from general revenues. The balance in the trust fund is being drawn down each year, since Medicare payroll tax receipts are less than trust fund obligations. Since the money in the trust fund is invested in treasury bonds, the fund gets the cash it needs by cashing in those bonds. To redeem the bonds, the treasury has to issue more debt.
And, since general revenues are less than expenses, the portion paid from general revenues would actually be paid from additional borrowing as well. So, by reducing the amount that would otherwise have been paid to MA plans, the ACA is reducing the net federal debt. The net debt would be the amount of real debt after excluding money the government owes itself (like the trust fund).
Taken together, I would expect a conservative think tank to argue in favor of reducing MA payments, to reduce the Part B premium and to reduce the net federal debt. The AAN position seems like a triumph of politics over policy, where an ostensibly conservative organization is promoting public subsidization of MA because a Democratic Congress took the conservative approach and cut the subsidies.
This report will probably be useful in ginning up some high dudgeon among conservative-leaning seniors whose conservative principles are somewhat plastic when it comes to getting government subsidies. Maybe it will help get out the vote in a few districts, if the target population remembers it come November. Otherwise, I'm not sure what the point of this is.
Resources
Find out what provisions in the final marketing guidelines will have the greatest impact on your organization and how plan sponsors can prepare for the upcoming changes in a webinar next Wednesday, July 23.
Part D and Hospice Rules Mucking Up Beneficiaries' Last Days
Last week the Centers for Medicare and Medicaid Services (CMS) met with 30 hospice & healthcare organizations about suspending a new rule intended to avoid duplicate payments for hospice medications. This is a very big deal and the new rule is mucking up many beneficiaries' last days. The National Hospice and Palliative Care Organization described the meeting as "an important first step at righting the wrongs being faced by dying Medicare patients."
Previously, hospice (under Medicare Part A) paid only for the drugs that patients needed for palliation and management of the terminal illness and related conditions, and Medicare Part D covered drugs for hospice patients' unrelated conditions. Under the new rule, CMS requires a beneficiary level prior authorization process for all hospice and Part D providers to determine responsibility of drug coverage, and hospice must cover medications related only to the hospice diagnosis.
CMS' expectations are unrealistic. Putting prior authorizations on everything adversely impacts beneficiary access to drug therapies and causes agonizing delays at the point of service. Consider this: first, it has to be determined if the drug in question is covered under Part A or D. If Part A, then you have to figure out if it's even covered under the hospice formulary and beneficiary refuses to try formulary equivalent first or drug is not reasonable or necessary per the hospice provider if not and the beneficiary wants the drug, it will be self-pay. If it's neither Part A nor D, then the beneficiary must self-pay. If covered under Part D and the prescriber is not hospice affiliated, the sponsor has to jump through hoops, including what to do if the prescriber is unable or unwilling to coordinate with the hospice provider.Then, if the drug has prior authorization on Part D it would have to satisfy those requirements. Plans have to be able to accept and save proactive determinations from hospice. It's an administrative nightmare. For 2014 only, CMS is universally allowing Plans to treat hospice coverage determinations as exceptions. That in and of itself shows that they are not sure how best to handle this mess.
With end-stage patients (the only kind you get in hospice), it is often difficult to discern which drugs are used for symptom management and what drugs are really for chronic conditions that if in hospice should not be treated, such as diabetes or hypertension meds. The hospice industry has reported widespread confusion and disputes that have made it harder for patients to get their drugs.
Seventy senators signed onto a letter circulated by Sens. Jay Rockefeller (D-WV) and Pat Roberts (R-KS), calling for CMS to suspend the rule. "We ask that CMS immediately suspend the Guidance and begin a process to develop an alternative approach which will ensure both that the right individual or entity pays for the hospice patient's medications and that the patient get the medication that he or she requires without interruption," they write.
We agree and hope CMS goes back to the drawing board on this rule. Calm and freedom from pain should define a beneficiary's last days, not administrative hoops and preauthorizations.
Resources
If you've just submitted your HEDIS data, now is the time to analyze that data for gaps and identify interventions for your health plans, providers and members. On July 17 join John Gorman, Executive Chairman at GHG, Jane Scott , Senior Vice President of Clinical Services and Anita McCreavy, Senior Consultant, for a webinar on HEDIS reporting, the new measures and what's next. Register now >>
The rapid changes to Part D regulations make the tracking and implementation of these CMS requirements exceptionally difficult — to say nothing of actually managing to them. Contact us today to learn how we can help >>
Further Evidence That PBMs are Failing on Government Programs
At CMS' oversight and enforcement conference last week Jonathan Blanar, the agency's Deputy Director of Compliance Enforcement, presented the following slide. In this slide, you will see actions CMS has imposed against Medicare health plans in the last two years, and for what reasons. It's further evidence that pharmacy benefit managers (PBMs) are failing Medicare beneficiaries and the plans enrolling them.
PBMs have a big hand in the first category, coverage determinations, though they're not entirely culpable. What's maddening about that tally is the fact that appeals and grievances rules in Medicare haven't changed much in the 17 years since they were first issued, and PBMs and plans are still screwing it up. To CMS, appeals are the most important consumer protection at the point of service, so they dish those findings out regularly.
It's the second category, formulary administration, that's most disturbing. The numbers speak for themselves. But Blanar added this color, the most frequent findings, which included the following and are a damning indictment of PBMs as the Keystone Kops of government programs:
- Unapproved quantity limits
- Unapproved utilization management practices
- Failure to properly administer the CMS transition policy
- Improperly effectuating a prior authorization or exception request
- Failure to provide a transition supply of a non-formulary medication
Resources
If you've just submitted your HEDIS data, now is the time to analyze that data for gaps and identify interventions for your health plans, providers and members. On July 17 join John Gorman, Executive Chairman at GHG, Jane Scott , Senior Vice President of Clinical Services and Anita McCreavy, Senior Consultant, for a webinar on HEDIS reporting, the new measures and what's next. Register now >>
The rapid changes to Part D regulations make the tracking and implementation of these CMS requirements exceptionally difficult — to say nothing of actually managing to them. Contact us today to learn how we can help >>
PBMs are the Health Plan Industry's Achilles Heel
In this Golden Age of government programs, the health plan industry has never had more exposure to the generally poor performance of pharmacy benefit managers (PBMs). Performance metrics in Medicare, Medicaid and ObamaCare are directly tied to PBM execution, and the recent track record of these companies means they are the Achille's Heel of insurers.
PBMs historically made most of their money on commercial insurance and have lagged on government programs, a trend exacerbated by a brain-drain of talent following a wave of PBM consolidation. The danger has never been greater for health plans, and their choice of vendor has never been more important.
First, Medicare's Star Ratings system has several critical performance measures directly tied to PBM performance, notably those related to drug plan service, formulary administration, patient adherence to drug therapies for chronic diseases like hypertension, and readmission prevention (many hospital readmits are due to drug over/underdose post-discharge). The numbers don't lie: Medicare Part D Star ratings and formulary administration were the two leading reasons for CMS-mandated corrective action plans dropped on insurers in the last year. Of plans scoring less than 2 Stars by performance domain, Drug Plan Customer Service came up worst in CMS's last review cycle -- followed by Member Experience with the Drug Plan, and Member Complaints, Problems Getting Care, and Improvement in the Drug Plan's Performance. It's a dismal record and getting worse.
Then consider that the two critically-important health plan quality improvement measures -- C33 and D07 -- are now weighted 5, a first for CMS and a huge development. The concern here is that PBMs are often terrible at data management, and under these measures a plan can be reduced to 1 Star where mishandled data resulted in bias or error, or where appeals and grievances handling is in question. With that 5-weighting, this has come as a rating killer for several plans and a major vulnerability for the rest, as most don't keep good logs of non-compliance issues or audit results.
PBMs are generally good at managing the drug benefits of commercial members, but the complexity of seniors and the low-income and the previously uninsured continues to confound these companies. Gorman Health Group ran 15 solicitations for government program PBM services for its clients in the last 12 months, and we wouldn't wrap fish in one of the responses we received. All varying degrees of suck.
In this last round of contract and service area expansions for 2015 Medicare Advantage and Part D, in our 18 years we have never seen more rejections due to PBM failings like pharmacy and home infusion network adequacy -- literally dozens this cycle, due both to PBM sloppiness and a new resolve at CMS to directly address it.
As PBMs continue to consolidate, plans need to protect themselves from weak execution by bringing renewed focus on PBM-directed Star ratings measures and most importantly, inspecting what they expect. The delegation oversight plan for this vendor is the most important document in compliance right now. Payers are now literally at the whim of the government programs sophistication of their PBM account manager, and that is not a comfortable place to be with literally billions of dollars and millions of seniors and the vulnerable hanging in the balance.
PBMs need to awaken to the new reality of the primacy of government programs today, and make a serious commitment to catching up.
Resources
If you've just submitted your HEDIS data, now is the time to analyze that data for gaps and identify interventions for your health plans, providers and members. On July 17 join John Gorman, Executive Chairman at GHG, Jane Scott , Senior Vice President of Clinical Services and Anita McCreavy, Senior Consultant, for a webinar on HEDIS reporting, the new measures and what's next. Register now >>
The rapid changes to Part D regulations make the tracking and implementation of these CMS requirements exceptionally difficult -- to say nothing of actually managing to them. Contact us today to learn how we can help >>
Tuesday Night's Primary Elections Were Huge. Here's What They Mean for Our Industry.
House Majority Leader, Eric Cantor (R-VA) is toast. Trounced in his Richmond district by a nobody Tea Bagger Tuesday night. Cantor gave up his leadership position yesterday. Depending on where you sit politically, either the unthinkable or the inevitable happened. In fact, a Majority Leader hasn't lost incumbency since the office was created in 1899. "The defeat of the second-ranking Republican in the House by an ill-funded, little-known tea party-backed candidate ranks as the biggest congressional upset in modern memory and will immediately generate a series of political and policy-related shock waves in Washington," wrote Chris Cilizza of WaPo.
What it means for our industry is that legislatively speaking, President Obama's second term is already over. The House will seize up like a bag of concrete in a toilet. The most unproductive Congress in history is about to continue and worsen that record as an epic Republican leadership battle ensues.
That means Obama is left chasing his agenda through administrative action, Executive Orders, regulations and enforcement. With brand-new and surprisingly popular HHS Secretary Sylvia Mathews Burwell on the job, expect her department to flex its muscles in ways we haven't seen, especially given the number of oversight hearings she's about to be subjected to:
- There will be tough new rules for all government-sponsored health programs: Medicare, Medicaid and implementation of the Affordable Care Act. The contentious new Part D rules are just the beginning.
- There will be increasing activism in network adequacy and rate reviews of insurers in Medicare Advantage, Part D and the exchanges;
- CMS will take a hard line on Medicare plans lagging in Star ratings and/or compliance records. The second term of a Democratic administration is always when scores are settled; the renewed Congressional scrutiny on our favorite agency will make the paper tiger grow some claws;
- CMS and the HHS Inspector General (IG) will finally put the pedal down on dreaded RADV audits with the promise of hundreds of millions in recoveries.
- With wingnuts like House Oversight Chairman Darryl Issa (R-CA) salivating for domestic Benghazis, the HHS IG will likely deliver a few surprises of its own.
Every time there's a major electoral event in Washington like this, elected and appointed officials alike will usually settle back on the motherhood and apple pie of health care politics: kicking the crap out of the insurance industry and other monied interests like pharmaceutical manufacturers and PBMs. If you're not wearing them already, it's time to pull on the kevlar boxers and the asbestos Spanx.
Aetna Offers a Playbook for Evolution in the Golden Age of Government Programs
Ralph Giacobbe of Credit Suisse got another terrific "get" hosting Aetna's management team for an insightful discussion last week. I found the takeaways offer a playbook for how to adapt and evolve in the new Golden Age of government-sponsored health programs:
Watch Your Wallet: Aetna assumed an accelerating cost trend in 2014 of 6-7%. The company noted that underlying cost trends remain generally muted and that overall drug spend is within expected ranges. The company's informatics and medical economics function tracks a wide range of data indicators for early warning of cost acceleration, and had nothing unusual to report.
Put the Pedal Down on the Government Platform: Aetna acquired Coventry for the purpose of having a seasoned platform for government business, so integrating the company remains a top priority for Aetna in 2014. You may recall Aetna called Fran Soistman, a legendary founder of Coventry and a battle-hardened veteran of Medicare Advantage and Part D, out of retirement to run its government business unit. He's been making huge progress in leveraging the company he built within Aetna. For instance, Aetna ranked #1 in price in 6 of 7 ObamaCare exchange regions in Florida, largely because of Coventry's footprint there. Aetna continues to expect $200M in synergies and $0.50 of accumulated accretion in 2014, and $400M in synergies and $0.90 of total accretion in 2015 from the Coventry acquisition.
Invest in Medicare Advantage Stars: Aetna invested heavily in Star ratings improvement the last two years, and now averages 4+ Stars. As a result, the bonus payment and favorable rebates it gets allowed the company to maintain competitive premiums and benefit designs for 2015 in the face of a 3-3.5% revenue headwind. The company remains positive on its competitive position, and expects to grow membership next year.
ObamaCare Exchanges in 2014-2015: This year Aetna is participating in 17 states and has 570,000 paid public exchange members, with management expecting to have 450,000 exchange lives by year end due to churn. The company booked some reinsurance in 1Q and now believes it may get the data to begin to factor in risk adjustment. Risk corridor remains more difficult to estimate and will evolve as experience matures. Aetna's exposure in the exchange market is limited to 5% of projected 2014 revenues and its guidance incorporates a modest drag on earnings. The company doesn't expect to expand its footprint in the ObamaCare exchanges in 2015 until it has a clearer picture on costs and the competitive landscape. Management suggested it would seek average high-single digit pricing increases for 2015 on the exchange -- and there's some comfort there as an early indicator that trends so far in the exchanges are not as crazy as the rate hikes of 15%-20% seen from other plans.
Aetna's perspectives, when considered against the backdrop of United's outlook for the next couple years, paints a picture of a rapidly-expanding government book of business that is gaining on its longtime commercial market dominance. It's a portrait of evolution in the Golden Age of publicly-sponsored health care.
Resources
Listen as John Gorman, Executive Chairman at Gorman Health Group and Josh Raskin, Managing Director at Barclays, discuss the recently released Stars data, and the seismic impact of the 8.5 billion quality demonstration. Access the podcast here >>
In this recorded webinar, John Gorman explores what "member centricity" means in today's government health care industry, at a time when consumerism is defining our relationships with members more than ever, and with CMS elevating quality improvement to game-changing levels. Download the webinar >>