COVID-19 and Value-Based Reimbursement: What Do We Know? Where Will it Go?

The impacts of COVID-19 on health care continue to unfold, and one area of uncertainty is the impact COVID will have on Value Based Reimbursements (VBR). Regardless of this uncertainty it appears that VBR is still trending upwards in behavioral health care.  Surveys conducted by OPEN MINDS demonstrate more use of episodic payments, case rates, and bundled rates. In one health plan survey, the number of health plans using bundled payments or case rates rose from 39% to 59% from 2017 to 2019 (see Trends in Behavioral Health: A Population Health Manager’s Reference Guide on the U.S. Behavioral Health Financing and Delivery System and What Are The Health Plans Doing About VBR?). And, a more recent survey of specialty provider organizations found that 24% of those organizations have some bundled rate contracts (see 2020 OPEN MINDS Performance Management Executive Survey: Where Are We On The Road To Value). A similar trend is noted in the public payer market, where a recent state-by-state analysis found that 28 of the 40 states with Medicaid managed care require health plans to implement alternative payment arrangements (APMs) with provider organizations. This is up from 22 states out of 39 states in 2017

With the continued growth of VBR, many questions about how the pandemic will change VBR processes remain. Some current trends shed light on this question. These trends also give providers clues about areas of focus moving forward in this ‘next normal’.

Shift to Telehealth

One of the astonishing developments of the pandemic is the phenomenal growth of telehealth utilization in behavioral health care. Telehealth has become ubiquitous during the pandemic. Some interesting results of a recent survey by Qualifacts and the National Council for Behavioral Health include:

  • Pre-pandemic, telehealth utilization in behavioral health care was relatively low, only 2% of organizations were providing 80% or more of their care virtually
  • Policy changes during the COVID-19 pandemic have reduced barriers to telehealth. Now, 60% of behavioral health organizations are providing 80% or more virtual care.
  • Behavioral health care executives expect the higher utilization of virtual services to continue, with a majority believing 40 % to 60% of their overall services will be provide in virtual platforms.

In the public sector, there have been sweeping changes in regulation and reimbursement for telehealth services. While the permanence of the changes in the public payer space has not been determined, it’s evident a system-wide reevaluation is occurring.  Some states have enacted new legislation already. For instance, On July 6, 2020, the Colorado legislature passed Senate Bill 212 to expand access to Medicaid telehealth services. The bill expands Medicaid coverage for telehealth services to include reimbursement at parity with in-person services at rural health clinics, federally qualified health centers (FQHC’s), and the Indian Health Service facilities.

Furthermore, the shift to telehealth is also be reinforced by the recent recognition by the National Committee for Quality Assurance (NCQA) revision of HEDIS Quality Measures associated with Telehealth utilization during the pandemic. https://bhmpc.com/2016/10/hedis-success-value-based-care/

New NCQA HEDIS Telehealth Rules

NCQA  adjusted 40 Healthcare Effectiveness Data and Information Set (HEDIS) measures—in response to the surge in telehealth during the pandemic (see NCQA HEDIS Quality Measures Adjusted For Increased Telehealth Use In Pandemic Crisis). The adjustments, published July 1, will go into effect in 2020 and include eight measures related to behavioral health—medication adherence, follow-up care after hospitalization or emergency department visits, and monitoring of co-occurring medical conditions in consumers with serious mental illness. For each measure, the updated guidance specifies how telehealth visits can be used and what will be included and excluded in the measure’s denominator and numerator. Most importantly, NCQA removed restrictions on video visits and now recognizes a video visit as the same as an in-person visit. Eight of the adjustments affect behavioral health measures (NCQA.org/COVID):

  1. Antidepressant Medication Management
  2. Follow-up Care for Children Prescribed ADHD Medication
  3. Follow-up After Hospitalization for Mental Illness
  4. Follow-up After Emergency Department Visit for Mental Illness
  5. Diabetes Screening for People with Schizophrenia or Bipolar Disorder Who Are Using Antipsychotic Medication
  6. Cardiovascular Monitoring for People with Cardiovascular Disease and Schizophrenia
  7. Diabetes Monitoring for People with Diabetes and Schizophrenia
  8. Adherence to Antipsychotic Medications for Individuals with Schizophrenia

The implication of the of the updated HEDIS measures is that telehealth coverage will carry forward to the post-crisis future. As noted by the NCQA, they cannot drive quality improvement “if their measures don’t take into account what has quickly become the fastest-growing modality for providing health care services.” For behavioral health providers who see telehealth as significant portion of outpatient services this is good news. It will also allow for more flexibility in designing programming to address VBR processes, especially when access to in person care is a major obstacle. https://www.ncqa.org/covid/

Payers are aware of the increase in utilization of telehealth and will build VBR programs around the assumption that provider are utilizing telehealth as part of their service array. Providers with fully integrated telehealth programming will be at a distinct advantage when it comes to VBR readiness in the post crisis era.

The use of telehealth is just one tool in a provider’s service array. Some COVID-19 other trends provide insight into post pandemic behavioral health utilization needs and potential cost drivers that may stimulate VBR development.

Systemic Impact of COVID-19

One interesting trend is the current underutilization of behavioral health services.  Many behavioral health providers have experienced significant decreases in utilization and revenue streams due to COVID-19, in large part due to increased unemployment from COVID-19 and the transition time of shifting benefits from private to public payer sources.

Juxtaposed against underutilization is the increase level of mental health conditions associated with the pandemic. It is expected that there will increase in levels of trauma, depression, and anxiety occurring as a result of the pandemic. The April 2020 Johns Hopkins COVID-19 Civic Life and Public Health Survey Wave 1 demonstrated a 10% increase in adults reporting serious psychological distress over 2019 reports. These results showed an exacerbation for adults with household income of less than $35,000 per year, 19% of whom reported serious psychological distress. There is also expected to be an increase in suicide rates. Unemployment is highly correlated with deaths by suicide, which has led experts to speculate that suicides will increase in 2020/2021. One model, based upon previous suicide and unemployment data, projects 3,235 to 8,164 additional deaths by suicide in the United States in 2020/20212

For payers and providers these trends will, at some point, create an increased demand for behavioral health services. Behavioral health providers with services that align to these needs, like expertise in areas of trauma informed care and crisis intervention programming, will be positioned to better serve these population health needs and meet the needs of payers who are looking for better outcomes for their consumers.

A second area of concern for all providers is the increase in opioid utilization. Due to increased opioid usage during COVID, mortality rates are expected to climb due opioid-related deaths. The American Medical Association (AMA) recently released a statement of concern about reports of increased levels of addiction and opioid-related mortality.

Value-based programs around addiction treatment have been on the rise since before COVID, both Cigna and Anthem have developed VBR programs that look at claims data in their private and public plan, tied that data consumer satisfaction surveys and outcomes. (See OPEN MINDS Addiction by the Numbers.) With the rise in opioid utilization it is reasonable to expect continued development of this treatment programming.

A Final Thought on Integrations

What is also interesting about VBR moving forward is the focus on screening, prevention, and integration of physical health care and behavioral health. Many states and national measures have incentivized screening for depression or substance abuse in primary care settings. And many plans are incentivizing referrals to co-located services and warm hand-offs where co-located services are not available. For forward-thinking behavioral health providers, the need for strong relationships with physical health care providers will present another opportunity for expanding their footprint and enhancing their revenue cycle through VBR arrangements. (See How VBR Prioritizes Primary Care as the Center of Integration.)

 

Learn more about Value Based Reimbursement with these resources from the VBCforBH.com Library.

  1. There Is No “Plan B” Alternative to Value Creating A Value-Focused Competitive Strategy in A Changing Market
  2. How to Develop Alternative Payment Models: A Guide to Building Effective Bundled Payment Models
  3. Care Delivery in A Value-Based Era – Evidence-Based, Practice-Based, Standardized & Measurement-Based
  4. Developing Case Rates? Better Find Your ‘Single Source of Truth’
  5. Adjust Your Strategic Sails!
  6. When the Competition Succeeds at Pay-For-Performance, What Will You Do?
  7. Options for Alternative Payment Models for Behavioral Health
  8. Using Your Performance Metrics to Build A Value Proposition for Health Plans

Nevada Cuts Medicaid Fee-For-Service Rate By 6%; Expects Annual Savings Of $53 Million

On August 15, 2020, the Nevada Medicaid program implemented a 6% rate cut to fee-for-service (FFS) rates. The Medicaid rate reduction is expected to save the state about $53 million over the coming fiscal year. The rate cut was directed by Assembly Bill 3 enacted by the Nevada Legislature during a Special Session to address a budget shortfall due to the coronavirus disease 2019 (COVID-19) pandemic and its subsequent economic impact. The state was facing a budget shortfall of nearly $1 billion. Assembly Bill 3 made a total of $130 million in cuts to the Medicaid program.

The state’s Medicaid managed care capitation rates will be amended by Nevada’s Actuary to include the impact of the 6% reduction to the FFS Fee Schedules, with an effective date of August 15, 2020. The total Medicaid caseload as of July 2020 is 716,981. About 27% (196,256 people) of these recipients are served through the fee-for-service program.

The 6% rate reduction affects behavioral health outpatient treatment, special clinic-addiction treatment agency model, psychologist, behavioral health rehabilitative treatment, applied behavior analysis, and inpatient psychiatric/substance abuse treatment services provided by a general acute hospital. However, rates will not be cut for the following behavioral health provider types and services:

  • Freestanding psychiatric hospital
  • Certified community behavioral health center
  • Residential treatment center
  • Federally Qualified Health Center

On August 14, 2020, the Nevada Department of Health and Human Services (DHHS) Division of Health Care Financing and Policy (DHCFP) notified provider organizations that it was also amending the application for the Home- and Community-Based (HCBS) Frail Elderly (FE) and Physical Disability (PD) Waiver to reflect the rate reduction. All FE and PD Waiver services will remain the same. The amendment must be submitted to the Center for Medicare and Medicaid Services (CMS) for approval. Comments will be accepted through September 14, 2020.

A link to the full text of “Nevada Medicaid Draft Home- and Community-Based Frail Elderly Waiver Amendment” may be found in the OPEN MINDS Circle Library at www.openminds.com/market-intelligence/resources/081520nvdrafthcbsfewaiveramend.htm.

A link to the full text of “Nevada Medicaid Draft Amendment For Home &Community Based Waiver For Persons With Physical Disabilities” may be found in the OPEN MINDS Circle Library at www.openminds.com/market-intelligence/resources/081520nvdrafthcbspdwaiveramend.htm

A link to the full text of “Nevada Assembly Bill #3: An Act Relating To State  Financial Administration” may be found in the OPEN MINDS Circle Library at www.openminds.com/market-intelligence/resources/071920nvassemblybill3.htm.

For more information, contact:

  • Division of Health Care Financing and Policy, Nevada Department of Health and Human Services, 1100 East William Street, Suite 101, Carson City, Nevada 89701; 775-684-3676; Fax: 775-687-3893; Email: dhcfp@dhcfp.nv.gov; Website: http://dhcfp.nv.gov/Contact/Contact_Home/
  • Submit comments on the draft waiver amendment to: Nevada Division of Health Care Financing and Policy, ATTN: LTSS – FE/PD Waiver Amendment, 1050 E William Street, Suite 435, Carson City, Nevada 89701; Fax: 775-687-8724; Email: hcbs@dhcfp.nv.gov

Colorado Expands Medicaid Telehealth Access

On July 6, 2020, the Colorado legislature passed Senate Bill (SB) 212 to expand access to Medicaid telehealth services. The bill expands Medicaid coverage for telehealth services to include reimbursement at parity with in-person services at rural health clinics (RHCs), federally qualified health centers (FQHCs), and the Indian Health Service facilities. The list of covered Medicaid telehealth services is expanded from health care and mental health care services to include speech therapy, physical therapy, occupational therapy, hospice care, home health care, and pediatric behavioral health care. Additionally, home health care provider organizations will be able manage telehealth services for Medicaid beneficiaries.

Mental health centers and addiction treatment centers are not listed among the provider organization types affected by the legislation. However, community mental health centers are among the types of provider organizations that are eligible to provide Medicaid fee schedule medical and other professional services for Colorado’s Medicaid program. Publicly funded telemedicine is covered for behavioral health provider organizations under the capitated behavioral health benefit administered by the Regional Accountable Entities (RAEs).

SB 212 also prohibits private payers from requiring an in-person exam before a physician can treat a new consumer via telehealth. Private payers cannot impose limitations on location, certification, or training as a condition of reimbursement. Additionally, SB 212 prohibits private payers from imposing any requirement or limitations on the use of HIPAA-compliant technologies to deliver telehealth.

The definition of telehealth was expanded from being synchronous (real-time) interaction-only between a consumer at an originating site and a health care professional located at a distant site to include remote monitoring technologies and store-and-forward transfers. Remote monitoring is defined as “the use of synchronous or asynchronous technologies to collect or monitor medical and other forms of health data for individuals at an originating site and electronically transmit that information to clinical professionals at a distant site so providers can assess, diagnose, consult, treat, educate, provide care management, suggest self-management, or make recommendations regarding a covered consumer’s health care.” The state will post data on telehealth use by August 6, 2020.

A link to the full text of “Colorado Senate Bill 212: Reimbursement For Telehealth Services” may be found in the OPEN MINDS Circle Library at www.openminds.com/market-intelligence/resources/070620coSB212.htm.

A link to the full text of “Telehealth Utilization In Health First Colorado From July 1, 2019 Through May 16, 2020” may be found in the OPEN MINDS Circle Library at www.openminds.com/market-intelligence/resources/072920cotelehealthstats.htm.

For more information, contact: Marc Williams, Public Information Officer, Colorado Department of Health Care Policy & Financing, 1570 Grant Street, Denver, Colorado 80203; 303- 866-2993; Fax: 303-866-2803; Email: marc.williams@state.co.us; Website: https://www.colorado.gov/pacific/hcpf/telemedicine.