Medicaid agencies want federal officials to keep them in mind as they incorporate participation in alternative payment models with all types of payers into Medicare's reimbursement rates for physicians.
The National Association of Medicaid Directors plans to launch a first-of-its-kind analysis to examine value-based purchasing already taking place across Medicaid programs and evaluate how those strategies align with initiatives underway in Medicare and the commercial insurance market.
In September, the CMS requested feedback on how it should implement new payment models in light of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which replaced Medicare's sustainable growth-rate formula with a program that relies on quality measures to drive reimbursement rates.
Beginning Jan. 1, 2019, a portion of physicians' payments will be based on their performance in a new “merit-based incentive payment program,” or MIPS. Physicians who get a significant amount of their revenue from alternative payment models can opt out of MIPS, and beginning in 2021, payment models outside of Medicare will count toward that threshold.
“We wanted to put this study out to get ahead of this,” said Matt Salo, the executive director of the National Association of Medicaid Directors. “No one has done a broad, sweeping look, at what Medicaid is doing in this space.”
Medicaid agencies in various states are experimenting with accountable care, pay-for-performance programs, bundled payments and shared savings models. The Medicaid association wants those efforts to be appropriately recognized into MACRA's multi-payer component.
It's important that CMS understand that there are fundamental differences between Medicaid and Medicare that affect the design and implementation of alternative payment models, the association says. For example, unlike Medicare, Medicaid is responsible for the majority of long-term services and supports and is the nation's largest public payer of behavioral health care.
The CMS also must account for that fact that Medicaid payment initiatives vary from state to state according to differences in the covered populations, political culture, budget parameters, administrative infrastructures, stakeholders, provider capacity and a host of other factors, the group says.