As of July 1, 2019, the Physicians Alliance, LLC (“ACO”) entered into a five (5) year and six (6) month Participation Agreement in the Medicare Shared Savings Program (“MSSP”) with the Centers for Medicare and Medicaid Services (“CMS”).
ACO’s governing body has duly authorized the below arrangements that qualify for the ACO Fraud and Abuse Waivers, and specifically the ACO Participation Waiver, through Resolutions adopted by unanimous written consent. The ACO Managing Board has made a bona fide determination that each arrangement is reasonably related to the purposes of the MSSP because it promotes accountability for the quality, cost, and overall care for a Medicare population as described in the MSSP, provides for the management and coordination of care for Medicare fee-for-service beneficiaries through ACO, and/or encourages investment in infrastructure and redesigned care processes for high quality and efficient service delivery for patients, including Medicare beneficiaries. Thus the ACO, pursuant to its governing body’s authorization, is asserting the ACO Participation Waiver’s protection over all of the ACO arrangements entered into as of the beginning of the current MSSP Participation Agreement term (July 1, 2019).
To comply with the ACO Participation Waiver’s requirements, the ACO is publicly disclosing the below arrangements. ACO will publicly disclose additional arrangements that qualify for the ACO Participation Waiver as they are authorized by its governing board on this website, in compliance with CMS’s public disclosure requirements.
ACO’s governing body made a bona fide determination that the arrangement between ACO, its Participants and Laboratory Corporation of America Holdings (“LabCorp”) are reasonably related to the purposes of the MMSP. As part of its efforts to: (1) promote better care for
individuals; (2) promote better health for populations; and (3) lower growth expenditures, ACO has contracted with LabCorp to assist in the implementation and on-going operation of care coordination in general and for the treatment and prevention ACO’s Medicare beneficiaries with chronic kidney disease. The care coordination support will help ACO facilitate its efforts to implement case management and care coordination of its MSSP attributed lives. As ACO implements the program across its ACO beneficiary population, ACO will promote the better health of populations and lower growth expenditures. (76 Fed. Reg. at 68000 and 68002).
Under the Supplier Value-Based Payments Arrangements, ACO may provide ACO participants with augmented payments for certain qualifying Medicare evaluation and management (“E&M”) services furnished to Medicare beneficiaries assigned to the ACO and billed through the ACO Participant’s TIN (not including copayments and deductibles paid by patient or Medicare supplemental plans). The amount of these augmented payments is dependent upon the achievement of certain performance metrics and value-based goals by ACO Providers/Suppliers as part of their care coordination with the ACO, including increased adherence to ACO quality assurance and improvement programs and evidenced-based medicine guidelines aimed at improving quality and efficiency of care, and compliance with specific timeliness, claims submission, and documentation requirements associated with those E&M services.
Under the Infrastructure Payments Arrangements, in order to fund ACO Participants’ infrastructure redesign of their primary care patient workflows, ACO may provide three months of supplemental payments above the Medicare Physician Fee Schedule amounts for certain pre-determined Medicare evaluation and management (“E&M”) services.
In coordination with Vytalize Health Inc., a management services organization, the ACO is entering into arrangements whereby it will subsidize the acquisition and maintenance costs associated with electronic medical records software and technical support services to further all of its ACO Participants’ efforts to effectively use information technology platforms for ongoing population health, quality improvement, and care coordination activities, which are primarily intended for the benefit of Medicare beneficiaries.
In coordination with Vytalize Health Inc., a management services organization, the ACO is entering into arrangements whereby it will subsidize certain telehealth and communications technology-based services, including but not limited to electronic medical record systems, care coordination software, and remote patient monitoring (collectively, the “Telehealth Services”).These Telehealth Services are intended to further ACO’s efforts to effectively use information technology platforms for ongoing population health, quality improvement, and care coordination activities for the benefit of Medicare beneficiaries being treated by ACO participants and ACO providers/suppliers, as those terms are defined within 42 C.F.R. Part 425.
In coordination with Vytalize Health Inc., the ACO is entering into arrangements whereby it will compensate primary care physicians and staff for attending meetings that support the treatment and coordination of care of Medicare beneficiaries treated by the ACO participants and ACO providers/suppliers, as those terms are defined within 42 C.F.R. Part 425. Staff will be compensated for proper coding review and related training. These meetings and training activities will allow the ACO to further advance its care coordination and quality improvement
efforts.
In order to enhance care coordination and manage the wellness of Medicare beneficiaries, the ACO, in coordination with Vytalize Health, Inc. and the IPA of Nassau/Suffolk Counties, Inc. (“IPANS”), an independent association of providers, is entering into arrangements whereby it will provide non-physician licensed clinical providers to physician group practices. These services are intended to further support the treatment and coordination of care of Medicare beneficiaries attributed to ACO participants and ACO providers/suppliers, as those terms are defined within 42 C.F.R. Part 425.
