Much of the long-term success of health care delivery and payment reforms proposed in the 1115 waiver will ultimately rest upon the details of the implementation of the accountable care organizations. MMS acknowledges that many of these details are outlined in the Health Policy Commission’s ACO certification, for which we provided extensive comment. The best designed MassHealth ACO will not be a sustainable model if the global budgets are not set at adequate rates that include special risk adjustment not just for physical health status but for mental health co-morbidities, long-term support and service needs, and social determinants of health. Funding for these global budgets need to be sustained over time, and must adjust for increases in wages, supplies, etc. Funding for other support services, such as the flexible funds that can be used for housing vouchers and medically appropriate foods, must be sustained as separate funding streams in the long-term, as well. Additionally, the quality and reporting standards should be consistent with other payers including Medicare, and physicians should be informed of the performance measurement expectations of an ACO, in order to best determine if they can meet or exceed expected quality and performance benchmarks that are outlined by the ACO. The Medical Society greatly appreciates the opportunity to provide these comments, and welcomes further discussion of any of these considerations.
Much of the long-term success of health care delivery and payment reforms proposed in the 1115 waiver will ultimately rest upon the details of the implementation of the accountable care organizations. MMS acknowledges that many of these details are outlined in the Health Policy Commission’s ACO certification, for which we provided extensive comment. The best designed MassHealth ACO will not be a sustainable model if the global budgets are not set at adequate rates that include special risk adjustment not just for physical health status but for mental health co-morbidities, long-term support and service needs, and social determinants of health. Funding for these global budgets need to be sustained over time, and must adjust for increases in wages, supplies, etc. Funding for other support services, such as the flexible funds that can be used for housing vouchers and medically appropriate foods, must be sustained as separate funding streams in the long-term, as well. Additionally, the quality and reporting standards should be consistent with other payers including Medicare, and physicians should be informed of the performance measurement expectations of an ACO, in order to best determine if they can meet or exceed expected quality and performance benchmarks that are outlined by the ACO. The Medical Society greatly appreciates the opportunity to provide these comments, and welcomes further discussion of any of these considerations.