1.0 PURPOSE OF AND AUTHORITY FOR
DEMONSTRATIONS
1.1 Section 1092, Chapter 55, Title
10 of the United States Code (USC) allows the Secretary of Defense
to conduct studies and demonstration projects. This section also
specifies that the Secretary may enter into contracts with public
or private organizations to conduct these studies and demonstrations.
1.2 This chapter will include notice
describing each value-based initiative, whether authorized under
Section 1092 or any other statute, designed to achieve such results
as including the improvement in:
1.2.1 Quality
of health care;
1.2.2 A beneficiary’s
experience in receiving health care; and/or
1.2.3 The health of beneficiaries.
1.3 Examples of statutory authority
authorizing value-based initiatives include the following:
1.3.1 The National Defense Authorization
Act (NDAA) for Fiscal Year (FY) 2016, Section 726 authorized one
or more demonstrations to determine whether the Department of Defense
(DoD) can reduce the rate of increase in health care spending and
improve health care quality, beneficiaries’ health, and beneficiaries’
experience of care by implementing one or more Value Based Purchasing
(VBP) initiatives.
1.3.2 Additionally,
the NDAA FY 2017, Sections 701(h), 705(a), and 729 authorized additional
VBP pilots to further explore the feasibility of incorporating VBP
into the purchased care sector of the TRICARE program.
3.0 BACKGROUND
3.1 NDAA FY
2016, Section 726 permits the Secretary to adopt a VBP initiative(s)
conducted by the Centers for Medicare and Medicaid Services (CMS)
or any other governmental or commercial health care program for
a TRICARE demonstration project. The size, scope, and duration of
the demonstration must be reasonable relative to the project’s purpose,
and the project’s criteria and data collection must enable proper
evaluation of value-based incentives to allow informed decision-making
regarding any future implementation of value-based incentives in the
Military Health System (MHS). Beneficiaries must have timely access
to health care during the project and not incur any additional financial
costs as a result of participation in the demonstration.
3.2 NDAA FY 2017, Section 701(h)
directs the Secretary to carry out a pilot program to demonstrate
and assess the feasibility of incorporating value-based health care
methodology in the purchased care component of the TRICARE program
by eliminating or reducing copayments or cost-shares for targeted
populations of covered beneficiaries in the receipt of high-value
medications and services and the use of high-value providers under
such purchased care component, including by exempting certain services
from deductible requirements. The amount of any reduction or elimination
of copayment or cost-share shall be credited towards meeting any
applicable deductible as if such reduction or elimination had not
been applied.
3.3 NDAA FY 2017, Section 705(a)
directs the Secretary to develop and implement value-based incentive programs
as part of any contract awarded under Chapter 55 of Title 10 USC
(10 USC 55), for the provision of health care services to covered
beneficiaries to encourage health care providers under the TRICARE
program (including physicians, hospitals, and other persons and
facilities involved in providing such health care services) to improve:
• The quality of health care
provided to covered beneficiaries under the TRICARE program;
• The experience of covered beneficiaries
in receiving health care under the TRICARE program; and
• The health of covered beneficiaries.
3.4 NDAA FY
2017, Section 729 directs the Secretary to implement programs to
improve health outcomes and control health care costs. Specifically,
this Section directs the implementation of medical intervention programs,
healthy lifestyle interventions, and healthy lifestyle maintenance
programs which may include lowering fees for enrollment in the TRICARE
program by a certain percentage or lowering copayment and cost-share amounts
for health care services during a particular year for covered beneficiaries
with chronic diseases or conditions described in
paragraph 2.0 who
met participation milestones, as determined by the Secretary, in
the previous year in such medical intervention programs.
4.0 GENERAL DESCRIPTION OF ADMINISTRATIVE
PROCESSES
4.1 In order to conduct a comprehensive
analysis of VBP in the MHS, all value-based initiatives will evaluate
a variety of value-based Alternative Payment Methodologies (APMs)
and incentives across multiple TRICARE markets. The Defense Health
Agency (DHA), the Services, and other key stakeholders will establish
a process for evaluating VBP concepts, determining which initiatives
would add value to the project, and designing and implementing appropriate
initiatives to be conducted in accordance with NDAA requirements.
4.2 At the Government’s discretion,
new VBP initiatives may be introduced at any time during the demonstration/pilot/program
period. Additionally, the Government may decide to revise the terms
and/or terminate existing VBP initiatives prior to the end of the
demonstration/pilot/program period.
4.3 When authority
exists to conduct a value-based initiative, Federal Register notice
shall be published describing the initiative and any statutory or
regulation provision that is being waived or modified by the initiative. If
existing statutory or regulation provisions will continue to be
implemented without interfering with the terms or conditions of
the initiative, no Federal Register notice is mandated.
However, for purposes of transparency, in general, Federal
Register notice will be given for all initiatives unless
the DHA Director determines that such notice will not be practicable,
in which case alternative forms of notice will be required to provide
transparency to the public in conduct of the TRICARE program.
4.4 Unless otherwise noted under
the specific administrative processes below, the contractor shall
provide quarterly written feedback to providers and hospitals in
the purchased care sector regarding their cost and quality performance
as compared to the established benchmarks for each value-based initiative.
These feedback reports shall be provided to VBP participating providers
and hospitals no later than 30 calendar days following the Government’s
completion of the data analysis.
4.4.1 The contractor
shall provide copies of all calendar year reports to the Director,
TRICARE Health Plan (THP). The format for these reports shall be
at the discretion of the contractor; however, the reports must clearly identify
the provider or hospital name and the value-based initiative period
of performance, and shall include all applicable data elements provided
in the Government’s quarterly data analysis.
4.4.2 The contractor’s reports shall
commence following the completion of the first full calendar quarter
of the demonstration/pilot/program (covering services provided since
the start date of the initiative) and every subsequent calendar
quarter thereafter.
4.5 Unless
otherwise noted under the specific administrative processes below,
the contractor shall provide annual feedback to VBP providers and
hospitals in the purchased care sector regarding their cost and
quality performance and their eligibility for a positive or negative
incentive (as determined by the Government). These feedback reports
shall be provided to VBP participating providers and hospitals no
later than 30 calendar days following the Government’s completion
of the annual data analysis and determination of positive or negative incentive
payments. The contractor shall provide copies of all annual reports
to the Director, THP. The format for these reports shall be at the
discretion of the contractor; however, the reports shall clearly
identify the provider or hospital name and the period of performance,
and shall include all applicable data elements provided in the Government’s
annual data analysis and incentive determination.
4.6 Unless otherwise noted under
the specific administrative processes below, any earned incentive payments
will be paid to VBP participating providers and hospitals on a retrospective
basis. Negative incentives, if applicable, will be withheld from
future claims payments. DHA will share data used in calculating
any incentives; however, the final dollar amount of any incentive
(positive or negative) is not appealable.
4.6.1 The recoupment
process outlined in
Chapter 10, Section 4 shall
apply to the collection of any negative incentives (including the
requirements for multiple demand letters and offsets). DHA will
provide the file to the contractor to initiate any necessary recoupments.
4.6.2 Negative collections shall
be recorded on non-underwritten bank reconciliation reports as a
non-TED “unable to adjust” collection.
Note: Although the final dollar amount
and calculation methodology are not appealable, the government may consider
recalculating if errors are identified.
4.7 Unless otherwise noted under
the specific administrative processes below, DHA will not recalculate
any incentives (positive or negative) after the analysis for each
demonstration/pilot/program year has been completed.
4.8 Unless otherwise noted under
the specific administrative processes below, one or more cohort
providers and/or hospitals will be identified in each market. These
cohort providers and/or facilities shall serve as control groups
for the VBP initiatives. Cohort providers and hospitals are not
eligible for VBP incentive payments regardless of their performance
during the value-based initiative. Cohort performance and data will
be used exclusively by the Government to assist in evaluating the
effectiveness of the MHS initiatives.
5.0 DHA RESPONSIBILITIES
5.1 The Director, DHA is the designated
Executive Agent for MHS value-based initiatives.
5.2 The Director, THP, is the DHA
Program Manager for MHS value-based initiatives.
5.3 The Director, THP, will designate
a project officer for each MHS value-based initiative.
5.4 DHA Contracting Officer (CO)
will add a Contract Line Item Number (CLIN) to the existing contract
(CLIN: VBP Incentives). The contractor shall invoice DHA for the
incentive payments to providers. The DHA Project Officer will analyze
and evaluate the worksheets showing calculations for positive incentives,
as well as negative incentives, and certify the amount due. If the
sum of the incentives results in a net-negative being owed to the government,
the negative amount due by the contractor will be collected against
other future incentive payments (network discount, network usage,
etc.).
6.0 CONTRACTOR RESPONSIBILITIES
6.1 The contractor shall maintain
sufficient staffing and management support services to achieve and maintain
compliance with all value-based initiative requirements as described
below.
6.2 The contractor shall educate
VBP participating providers and facilities regarding the goals,
terms and conditions of the initiative.
Note: The contractor is not required
to educate cohort providers or hospitals; however, information will
be shared upon request.
6.3 The contractor
shall continually monitor access to care for VBP participating providers
and hospitals according to existing TRICARE requirements. The contractor
shall contact DHA within five calendar days if it is determined
that VBP participation is adversely impacting access to care.
9.0 RESTRICTIONS ON SCOPE OF BENEFITS
FURNISHED UNDER DEMONSTRATION PROJECTS
9.1 Proposed
new benefits provided under demonstration authority must receive
DHA coordination in the same manner as any other proposed TRICARE
benefit; and
9.2 Unless specific statutory demonstration
authority provides otherwise, benefits may not be provided under
a demonstration project that would otherwise be considered unproven
under TRICARE Standard through December 31, 2017 or TRICARE Select
starting January 1, 2018.