The Centers for Medicare & Medicaid Services (“CMS”) recently announced the Community Health Access and Rural Transformation (“CHART”) Model, which is a new voluntary payment model aimed at increasing access to and improving the quality of health care in rural communities through a value-based rather than volume-based approach. Under the CHART Model, Accountable Care Organizations (“ACOs”), Acute Care Hospitals and Critical Access Hospitals located within or providing services to rural communities can participate in one of two Transformation Tracks. Both Tracks are designed to address the many challenges associated with transforming health care delivery systems in rural communities. Within each Track, CMS will provide upfront financial incentives, operational and regulatory flexibility and technical support in an effort to:
- Improve access to care in rural areas;
- Improve the quality of care and health outcomes for rural beneficiaries;
- Increase adoption of alternative payment models (“APMs”) among rural providers; and
- Improve rural provider financial sustainability.
Community Transformation Track
The Community Transformation Track will involve a single entity (referred to as the Lead Organization) that represents a rural community as defined by census tracts and the Federal Office of Rural Health Policy. The CMS announcement lists Medicaid agencies, State Offices of Rural Health, local public health departments, Independent Practice Associations and Academic Medical Centers as examples of entities that may serve as Lead Organizations. The Lead Organization will work with Model Participants (described below) to implement a customized, community-wide redesigned health care delivery strategy.
Key Points
- Up to 15 Lead Organizations will be selected to participate in this Track of the CHART Model.
- Each Lead Organization will work closely with Model Participants to design a plan that best suits the needs of the specific community, and each Lead Organization will be provided up to $5 million to fund the community plan.
- Each Model Participant must be:
- An acute care hospital; or
- A Critical Access Hospital that:
- Is located within the community and receives at least 20% of its eligible Medicare fee-for-service (“FFS”) revenue from services provided to residents of the community; or
- Provides services to residents of the community that in aggregate account for at least 20% of the eligible Medicare FFS expenditures of the community.
- FQHCs, RHCs, stand-alone ASCs, SNFS, HHAs and dialysis centers are expressly excluded as Model Participants, although it is possible that CMS will permit such entities to act as Lead Organizations.
ACO Transformation Track
The ACO Transformation Track aims to build upon the ACO Investment Model by providing advanced payments to rural-focused ACOs participating in the Medicare Shared Savings Program. CMS hopes to encourage CHART ACOs to implement value-based payment strategies to improve health care for rural beneficiaries.
Key Points
- Up to 20 ACOs will be selected to receive advanced shared savings payments for participation in one-sided or two-sided risk arrangements in the Medicare Shared Savings Program.
- An ACO is eligible for this CHART track if it meets specific rurality requirements and participates in the Shared Savings Program for the entirety of the agreement period. CMS may also release additional eligibility requirements for this CHART track.
Practical Takeaways
- The CHART Model will allow providers focused on rural communities to receive support and test the potential benefits of creating and implementing a value-based payment model that can be customized to each community’s specific needs. As such, rural health care providers that are confronting challenges with health system alignment, transportation, health care provider shortages and/or technological hurdles may benefit from participating in the CHART Model.
- Prospective participants should begin considering their options, as applications for the Community Transformation Track and ACO Transformation Track will be due February 2021 and summer 2021, respectively. The Notice of Funding Opportunity for the Community Transformation Track is available as of September 15, 2020, and the ACO Request for Application will be available in early 2021.
If you have questions related to the CHART Model or would like to discuss how you can take advantage of this initiative, please contact:
- Jennifer Skeels at 317.977.1497 or jskeels@hallrender.com;
- Brian Betner at 317.977.1466 or bbetner@hallrender.com;
- Megan Culp at 317.429.3644 or mculp@hallrender.com; or
- Your regular Hall Render attorney.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
