This installment of Hall Render’s Health Law Broadcast series on health care reform is designed to provide you with the insight, analysis and practical suggestions with respect to the various reform initiatives that will affect your organization.
Overview
On December 21, 2011, CMS issued a notice soliciting applications for the Independence at Home (“IAH”) Demonstration, a program established under Section 3024 of the Affordable Care Act to provide a complete range of home-based primary care services to chronically ill Medicare beneficiaries for a three-year period. The purpose of the IAH Demonstration program is to determine whether coordinated and comprehensive medical care in the home can keep chronically ill patients healthier and out of the hospital while saving money for the Medicare program and improving patient and caregiver satisfaction. With the launch of the IAH Demonstration program, house calls are back. Home-based care delivery may well prove to be the ideal model for management of patients with complex medical problems.
Mechanics of the Program – Clinical Aspects
Primary care medical practices led by physicians or nurse practitioners with experience providing home-based primary care to patients with multiple chronic conditions and serving at least 200 chronically ill patients per year are invited to participate in the program. Participation by beneficiaries is voluntary. To be counted as one of the threshold 200 required for practice participation, Medicare beneficiaries must:
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Have at least two chronic conditions;
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Require assistance with at least two activities of daily living (e.g., bathing, walking, dressing);
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Have had a non-elective hospital admission within the last 12 months;
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Have received rehabilitation services within the last 12 months; and
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Be covered under fee-for-service Medicare and not enrolled in Medicare Advantage, a Program for All-Inclusive Care for the Elderly, or a practice that is part of the Medicare Shared Savings Program or other program that shares Medicare savings.
Participating practices would consist of ancillary personnel such as pharmacists, social workers, physician assistants and other support personnel, in addition to the team leader physicians/nurse practitioners. Under the program, team members would make in-home visits customized to the needs of each beneficiary, and the practice must be available 24 hours/day, 7 days/week to implement plans of care. In addition, practices must use electronic health records, remote monitoring and mobile diagnostic technology. A practice may apply to participate in one of three ways: (1) as a sole legal entity; (2) as a member of a consortium of primary care practices within a geographic area; or (3) as part of a national pool of providers. The IAH Demonstration program may include up to 10,000 beneficiaries and up to 50 practices.
Incentive Scheme
Under the IAH Demonstration program, CMS will calculate a “spending target” based on expected Medicare fee-for-service expenditures under Medicare Parts A and B for each of the participating beneficiaries, absent the Demonstration program. Savings to the Medicare program will be calculated based on the difference between a practice’s (or consortium’s or national pool’s) spending target and actual costs incurred. It is anticipated that patients treated by a multidisciplinary team in the home will make fewer emergency department visits and be hospitalized less frequently, resulting in projected savings to the Medicare program. If practices meet certain quality performance standards established by CMS, they will be eligible to receive incentive payments consisting of a share of the savings achieved. Of note, the practices will continue to bill and collect under the standard Medicare fee-for-service payment system, and there is no penalty for not achieving savings.
Application Deadline
Eligible practices meeting the criteria for admission to the IAH Demonstration program must submit an application no later than February 6, 2012 at 5 p.m. EST. Applicants must submit at least one electronic copy on CD-ROM of the application and a paper copy with an original signature. File code [CMS-5048-N] should be referenced on the application. The Federal Register Notice of the IAH Demonstration program may be found by clicking here.
Additional application information, the application and a helpful list of FAQs, as well as other resources may be found on the IAH Demonstration website by clicking here.
CMS recommends that interested parties subscribe to the listserve to receive the most up to date information.
If you have any questions or would like additional information about this topic, please contact Adele Merenstein at (317) 752-4427
or amerenst@hallrender.com, Rene Remek Savarise at (502) 568-9365 or rrsavarise@hallrender.com or your regular Hall Render attorney.
Please visit our Health Care Reform site for current information and resources regarding health care reform issues and regulations.
