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A Framework for Paying for Social Determinants of Health Presentation for SNP Alliance October 11, 2013 Purpose of Paper Current MA P4P increases resources for plans that provide better quality care and reduces resources for plans when disparities are measured Recent paper commissioned by Amerigroup (now Wellpoint) suggests: Current MA P4P could disadvantage plans that serve a disproportionate share of beneficiaries with LOW socioeconomic status (SES) Solutions include adjusting more MA quality measures for case mix (including SES) and rewarding quality improvement This paper looks more broadly at how Medicare payment can be designed to reflect socioeconomic status and related “downstream” factors Characteristics of SNPs SNPs enroll a disproportionate share of dual eligibles Dual eligibles have higher poverty, high prevalence of no high school education, more racial and ethnic representation, miniscule rates of retiree coverage 90% SNPs vs 20% FFS i.e., low socioeconomic status SNPs have perspective and experience that can help educate policymakers about the effects of socioeconomic status on health SNP experience can inform design of health policy solutions for Congress Socioeconomic Status Affects Health Research concludes SES plays a significant role in a person’s health Research has found a host of social factors “downstream” from SES that affect health Low SES affects how individuals use health care and their health outcomes SES deemed a “determinant” of health, like biological factors – age, sex, genetics Differences in SES and related factors can lead to disparities in health outcomes Health literacy, access to transportation/social supports, health behaviors, neighborhood Many but not all downstream factors within sphere of influence of health system SES not within sphere of influence of health system but can help identify/target interventions that reduce SES-related health disparities Conceptual Framework for Determinants of Health Age, Sex, Genetics SOCIAL DETERMINANTS Socio-economic Status (SES) Race/Ethnicity/Culture Neighborhood MEDIATORS/MODERATORS: Health Literacy/Language Transportation/Social Supports BEHAVIORS: USE OF CARE: Smoking Diet/Nutrition/Exercise Substance Abuse Preventive Screenings Doctor vs ER Visits Treatment Adherence MEDICAL ILLNESS: z Acute/Chronic OUTCOMES: Quality and Cost of Care CONDITIONS: Drug Dependence, Frailty Homelessness Scope of Health Plan BIOLOGICAL DETERMINANTS: Twelve Social Factors of Concern to SNPs SNP Alliance identified 12 social factors that they view as most challenging for beneficiaries and plans in the care delivery process Criteria Could Help Select Social Factors for Medicare Payment Criteria could be applied to SNP identified factors and universe of social factors found to affect health in order to select ones most appropriate for Medicare payment Strong base of evidence that social determinant affects health Complexity/severity of illness is increased by social determinant Proximity to providers and plans, i.e., within sphere of influence of health system Social determinant links to other social factors for possible spill-over effects Degree of social/political acceptance of need to address Role of Race and Ethnicity Racial and ethnic groups are a growing part of the Medicare population SNPs enroll racial/ethnic groups at higher rates than traditional Medicare and non-SNP MA plans Minorities experience worse outcomes (greater illness and mortality) than non-minorities Focus of social epidemiological research has been on racial/ethnic health disparities , more than SES health disparities Institute of Medicine concerned that some racial/ethnic health disparities stem from discrimination in the health system A goal of this Administration is to reduce disparities in wages, health care, social justice Relationship between race/ethnicity and health is complicated by strong correlation with SES Overlap in reducing racial/ethnic health disparities will be created by addressing SES health disparities SES and downstream social factors are relevant as means to address health disparities of all kinds Goals of Medicare Payment Medicare payment policy has focused on 3 main goals: Payment accuracy Encouraging efficient use of services Ensuring access to care Broad national policy goals have been addressed through Medicare payment In general, Medicare payment does not account for social determinants Graduate medical education, access to care in rural areas Exception: Medicaid status included in MA risk adjustment model Current Medicare payment design could incorporate social determinants Policymakers asked: would such a payment add new resources to the system or be budget neutral? Components of MA and FFS Payment Both FFS and MA payment systems have 3 components Base Pay = core payment per unit of service , per patient or per person Adjustments to base pay = multipliers to base pay Add-ons or separate payments = separate lump sum payment ACA added new quality bonus adjustments (pay for performance) to payment for both MA plans and FFS acute-care hospitals P4P planned for other FFS settings Components of MA Payment Capitated Rate (= Plan Bid if Bid is Below Benchmark) x Plan-Level Characteristics: --Varies by Star Rating Health and Demographic Risk Adjustment Person-Level Characteristics: --Diagnosis --Age/Sex --Medicaid status --Disabled status --Working aged status + Rebate (Add On) Plan-Level Characteristics: --Adjusted by plan-level risk adjusted benchmark --Varies by Star Rating Base Rate = Plan Bid Risk Adjustment = demographic (age/sex) and health (limited to 70 diagnoses), 1 social (Medicaid status proxy for income) Add On = rebate for financial efficiency, must fund new benefits Current Adjustments to MA Capitated Payment BIOLOGICAL DETERMINANTS: Age, Sex, Genetics SOCIAL DETERMINANTS Socio-economic Status (SES) SSI Status, Education, Occupation Race/Ethnicity/Culture Neighborhood POSSIBLE MEDIATORS: Health Literacy/Language Transportation Social Supports Smoking Diet/Nutrition/Exercise Substance Abuse MEDICAL ILLNESS: CONDITIONS: Acute (AMI) z Chronic (Obesity/Diabetes/COPD/CHF) Drug Dependence Frailty Homelessness OUTCOMES: Quality and Cost of Care = included in MA payment USE OF CARE: Preventive Screenings Doctor Visits Emergency Room Treatment Adherence Scope of Health Plan BEHAVIORS: Components of FFS Payment x Area Wages Prospective Payment x Area Wages + x Physician Fee Schedule Adjustments (1 and 2) + Add-on: area level adjustment for health Add-on professional shortages Add-on (Base Rate) 1. Patient Level Adjustments (facility) -Diagnosis/case-mix (hospitals) -Complication/comorbidity (hospitals) -Age (IRF, Dialysis, Psych) -Cognitive status (IRF) -Functional status (IRF) -Sex (LTCH) 2. Facility-Level Adjustments (facility) -RuraTeaching status (Psych) -l location (IRF) -Share of low income (IRF) Add-On (purpose/facility) -Indirect GME (teaching/acute care) -DSH (low-income/acute care) -Rural (access to care/acute care) -Hold harmless payments (outpatient) Components of FFS Payment Base rate = fee schedule or prospective payment Adjustments = area wages + patient level adjustments + facility level adjustments Patient level varies, reflects demographic (age/sex), diagnoses, functional status Facility level reflects teaching/rural status, share of low income benes served Exclude SES factors Add on = separate payment to achieve national policy goals: Graduate medical education Access to rural providers Financial viability of hospitals that serve low income populations Quality Bonus Payment (P4P) ACA added quality bonus “adjustments” to both MA and FFS base payments P4P has potential to improve quality outcomes and reduce health disparities in Medicare Caveat: Medicare P4P could exacerbate SES-related health disparities in Medicare as unintended consequence Only CAHPS measures are adjusted for case-mix (reflect includes health status, demographics and education) MedPAC: broaden case-mix adjustment of hospital all-cause readmissions measure to include income/SES Same argument can be made for all outcome measures and those that are clinically-based Issue of whether socioeconomic status should be included in case mix adjustment of quality measures will need to be addressed Lack of case mix will have larger effects over time as more health outcomes measures are being added to P4P Should providers/plans be held accountable for differences in patient quality that derive from differences in SES? NQF informed SNP Alliance that CMS has asked NQF to address this question Options for Designing Payment that Reflect Social Determinants of Health 1. Modify MA risk and FFS case-mix adjustments in order to reflect effects of social characteristics of patients on costs of care Incorporate measures of SES or other social characteristics of beneficiaries into the risk/case-mix models Per MedPAC, adding race/ethnicity and income does not improve accuracy of the MA risk model Include/interact in the risk/case-mix models more diagnoses that are highly correlated with SES For example, substance abuse could be interacted with several diagnoses in MA risk model 2. Modify P4P to control for independent effects of SES on health outcomes Apply case-mix adjustment to all outcome measures and broaden case-mix adjustment to include more SES factors of beneficiaries Options for Designing Payment that Reflects Social Determinants of Health 3. Create separate payment to reduce health disparities linked to SES disparities Addressing SES disparities will reduce racial/ethnic disparities Not all plans would qualify, i.e., plans enrolling more beneficiaries with higher SES would not likely receive added payment 4. Create new payment adjustment to reduce health disparities linked to SES Adjust base payments for social status, not just health and case-mix Example: 1 percent adjustment in base rates in areas that have SES or quality disparities among Medicare beneficiaries Potential Adjustments or Add-Ons to MA Capitated Payment Key Data Considerations Data issues will be a major consideration in any new payment policy, including: Does necessary data exist that identifies social characteristics/determinants of Medicare beneficiaries? If so, at what level (beneficiary, plan, geographic area)? Who collects the data? Can the data be gamed? Policymakers are skeptical of descriptive data collected by providers or plans, more comfortable with data collected by Social Security or other agencies If no data exists, could it be readily collected? By whom? At what level? Is it gamable? Is the data accurate? Data Issues for 12 Social Factors of Concern for SNPs Other Considerations in Medicare Payment Policymakers may be concerned with other issues when considering any new Medicare payment: Should payment modification or new payment be linked to results? ACA ushered in a new era of accountability If goal is to reduce disparities, then how could policymakers know payment is working? Should payment modification or new payment add resources to Medicare or be designed to be budget neutral? Would payment modification or new payment duplicate Medicaid or other federal programs designed to address same or similar issue?