On June 29, 2012, The Joint Commission (“TJC”) released proposed requirements for the certification (“Certification Requirements”) of Primary Care Medical Homes, also known as Patient Centered Medical Homes (“PCMH”). Although the certification will not be available until early 2013, TJC is seeking comments on the Certification Requirements until August 10, 2012.
Background
A prominent feature of the Patient Protection and Affordable Care Act, PCMHs are designed to increase patient access to more comprehensive, coordinated primary care, thus reducing health care costs through preventative care and more structured follow-up care. In the PCMH model, a primary care physician leads an interdisciplinary team of health care providers to ensure that all facets of a patient’s health care needs, whether preventative, acute or chronic, are addressed in the most efficient manner possible utilizing the best evidence and technology available.
Often confused with the concept of Accountable Care Organizations (“ACOs”) because both ACOs and PCMHs share a common goal of care integration, a PCMH is often a necessary, though not mandatory, component of a successful ACO because a PCMH offers care coordination at the fundamental primary care level, which in turn strengthens care integration for the ACO. The concept is that when an efficient primary care provider coordinates care for a patient through a medical home, such care coordination yields increased quality and cost-effective care, while simultaneously providing a platform to aid in the essential communications among the patient’s providers that is critical to ACO functionality.
Although TJC currently has an optional PCMH certification process in place for ambulatory care organizations that are not hospital-based, the new certification program is intended to create requirements for certification of hospital PCMHs. The ambulatory care certification currently maintains 52 requirements in addition to those needed for general ambulatory care organization accreditation by TJC. As of July 23, 2012, there were 25 ambulatory care organizations with TJC PCMH certification.
Summary
The optional hospital PCMH certification is designed to enable “improvements in quality of care and patient safety achieved through accreditation to be combined with the potential for increased reimbursement.” The certification is available only to hospital-based ambulatory health care organizations and, if elected, is designed to be an optional addition to TJC hospital accreditation. TJC has identified five fundamental attributes (as well as the concepts that, in combination, comprise such an attribute) that must be possessed by an organization wishing to be certified as a PCMH, as follows:
Patient-centered care
- Primary care clinician chosen by the patient
- Primary care clinician and interdisciplinary team work as a unit with the patient
- Patient’s cultural, linguistic, language and education needs taken into consideration
- Establishment of treatment plan with input from the patient
- Provide support for patient self-management
Comprehensive care
- Provision of acute, preventative and chronic care
- Provision of continuous and comprehensive care
- Use of an interdisciplinary team approach to provide care
- Primary care clinician has sufficient education and knowledge to resolve conflicts in the patient’s care recommendations and to handle most of the patient’s medical needs
- Primary care clinician works in collaboration with the interdisciplinary team
- Care addresses all stages of the patient’s life
- Disease management
Coordinated care
- Internal and external resources used to meet the patient’s needs
- Responsibility for care coordination
- Team-based approach
Excellent access to care
- Enhanced access via flexible hours and days of service, variety of communication methods and shorter wait times for urgent needs
- Information regarding scheduled appointments available at all times
- Access for non-visit-related patient needs
- Access for patients with unique communications needs
A systems-based approach to quality and care
- Population-based care
- Use of health information technology
- Primary care clinician and interdisciplinary team function within scope of practice, observing applicable laws, regulations and privileges
- Use of evidence-based methods and decision support tools
- Provision of care to a panel of patients
- Patient involvement in performance monitoring and improvement
Conclusion/Practical Takeaways
The proposed PCMH certification creates a set of uniform standards that, if adopted, could be the necessary step for PCMHs to achieve Medicare reimbursement. Hospitals embarking on PCMH models of care (particularly those hospitals with ambulatory care settings) should consider TJC’s proposed PCMH certification requirements and whether such PCMH modeled care strategies currently meet the proposed PCMH requirements for certification. In addition, such hospitals may want to consider submitting comments to TJC regarding the appropriateness of the proposed PCMH certification requirements, especially in cases where the requirements may have a negative impact operationally.
Review of TJC PCMH certification proposed requirements and submission of comments may be made here.
If you have any questions or would like additional information on this topic, please contact Andrea Impicciche at 317.977.1578 or aimpicciche@hallrender.com, Elizabeth Mitchell at 317.977.1401 or emitchell@hallrender.com or your regular Hall Render attorney.
