payment models, including consenting providers upon go- of prospective payment in live. This is critical to align which providers may elect to incentives and make internal have some of their fee financial architecture work schedule payments reduced or correctly. withheld, and instead paid directly to the ACO. 4.1.4.2 If an ACO designates a referral We do not believe that taking 27 circle, that MassHealth off all referral requirements is a approves the enrolled member good tool to promote care will not need a primary care coordination. Although this referral for any services might have theoretical merit, in rendered by a provider in that reality, it promotes unnecessary ACO’s referral circle, making it utilization, regardless of the easier for members to receive preferred circle. Our PCPs are coordinated care. not in favor of referral circles. Preferred specialists should also be concerned that removing a referral requirement will allow unnecessary care to get to them. You should keep referrals in place for all non- ACO provided services. However, we are very supportive of adding more meaningful administrative requirements for non-preferred providers (eg; authorization or ACO generated referrals with unique numerical sequencing), and we encourage you to seek approval to do so in this Waiver Request. 4.1.4.3 Model B ACOs must have a MassHealth must be able to 27 repayment mechanism a line implement withholds upon go- – of credit, restricted capital live as this can be an internal reserve, or performance bond strategy to create a reserve – to ensure they can bear the fund for funding a portion of financial responsibilities of the repayment obligations (ie: an ACO risk model. ACO PCP claims withhold). We would like to be able to select the amount from 1% up to 15%. 4.1.6 Accelerate the We are in full and complete 28 readiness work that agreement with this statement. ACOs are performing during this period 10 Gove St, East Boston, MA 02128 617-852-4709
payment models, including of prospective payment in which providers may elect to have some of their fee schedule payments reduced or withheld, and instead paid directly to the ACO. consenting providers upon go- live. This is critical to align incentives and make internal financial architecture work correctly. 4.1.4.2 27 If an ACO designates a referral circle, that MassHealth approves the enrolled member will not need a primary care referral for any services rendered by a provider in that ACO’s referral circle, making it easier for members to receive coordinated care. We do not believe that taking off all referral requirements is a good tool to promote care coordination. Although this might have theoretical merit, in reality, it promotes unnecessary utilization, regardless of the preferred circle. Our PCPs are not in favor of referral circles. Preferred specialists should also be concerned that removing a referral requirement will allow unnecessary care to get to them. You should keep referrals in place for all non- ACO provided services. However, we are very supportive of adding more meaningful administrative requirements for non-preferred providers (eg; authorization or ACO generated referrals with unique numerical sequencing), and we encourage you to seek approval to do so in this Waiver Request. 4.1.4.3 27 Model B ACOs must have a repayment mechanism – a line of credit, restricted capital reserve, or performance bond – to ensure they can bear the financial responsibilities of the ACO risk model. MassHealth must be able to implement withholds upon go- live as this can be an internal strategy to create a reserve fund for funding a portion of repayment obligations (ie: an ACO PCP claims withhold). We would like to be able to select the amount from 1% up to 15%. 4.1.6 28 Accelerate the readiness work that ACOs are performing during this period We are in full and complete agreement with this statement. 10 Gove St, East Boston, MA 02128 617-852-4709
appendix-c-public-comments.docx