1.0 Purpose
In addition to the authority
under Section 1092, Chapter 55, Title 10 of the United States Code
(USC) which allows the Secretary of Defense to conduct studies and
demonstration projects as described in
Chapter
18, other statutory provisions specifically authorize
the Secretary to conduct TRICARE VBP initiatives. This chapter (Chapter
29) shall 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: (a) quality
of health care; (b) a beneficiary’s experience in receiving health
care; and/or (c) the health of beneficiaries. Examples of statutory
authority authorizing value-based initiatives include the following:
1.1 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
VBP initiatives.
1.2 Additionally, the NDAA for
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.
2.0
Background
2.1 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.
2.2 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.
2.3 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, United States Code (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.
2.4 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.
3.0 Policy And Eligibility
3.1 In the purchased care sector,
both network and non-network providers and facilities will be considered
for demonstration/pilot/program participation based on TRICARE utilization
and other factors selected by the Defense Health Agency (DHA). In
the direct care sector, Military Treatment Facilities (MTFs)/Enhanced
Multi-Service Markets (eMSMs) may be considered for participation
at the request of the Services or DHA. Specific provider/hospital
and beneficiary eligibility criteria are described within the detailed
administrative processes for each value-based initiative described
in this section.
3.2 Upon DHA’s
identification of one or more providers or facilities for a specific
value-based demonstration in the purchased care sector, the appropriate
regional contractor shall contact the provider or hospital and provide
details of demonstration/pilot/program participation as appropriate. These
details include any DHA decision to make participation in a VBP
initiative mandatory for purchased care sector providers and facilities.
The contractor shall contact DHA within five calendar days if:
• A network provider or hospital
indicates, either verbally or in writing, that they refuse to renew
their network agreement as a direct result of VBP participation,
or
• A non-network provider or hospital
indicates, either verbally or in writing, that they intend to deny access
to TRICARE beneficiaries as a result of VBP participation.
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. 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 days following the Government’s completion
of the data analysis. 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. 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 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.
7.0 Applicability
Value-based initiatives are
applicable to TRICARE beneficiaries who receive care from designated
VBP participating providers or hospitals within the 50 United States
and the District of Columbia. Refer to specific administrative processes
below for a description of the beneficiary population for each demonstration/pilot/program.
8.0 Exclusions
Unless otherwise noted, TRICARE
beneficiaries with Other Health Insurance (OHI), beneficiaries enrolled
in the TRICARE Overseas Program (TOP), TRICARE Medicare Eligible Program (TMEP) beneficiaries,
and beneficiaries in the Continued Health Care Benefit Program (CHCBP)
are excluded from all value-based initiatives. Refer to the specific
administrative processes in the specific pilots for additional exclusions
that may apply to an individual initiative.