Dear Texas RHC,
Below is information on a possible grant for RHCs in Texas. Survey responses are due by 2/17/21.
Stakeholder Information
Please fill out the information below in case HHSC needs to reach out to you for more information. 1.First Name John
2.Last Name Henderson
3.Email Address jhenderson
4.Organization Name Texas Organization of Rural and Community Hospitals (TORCH)
RAPPS – Component 1 Measures for Year 1
Please provide feedback on the following Component 1 structure measures. Refer to the RAPPS Specifications Excel file for additional details. The specifications file is located at DSRIP Transition Website https://hhs.texas.gov/laws-regulations/policies-rules/waivers/medicaid-1115-waiver/dsriptransition under Transition Milestone Updates.
Component 1 structure measures require semi-annual reporting of status/progress. Year 1 Component 1 reporting is tentatively planned to take place during Quarter 1 (September-November 2021) and Quarter 3 (March-May 2022).
5.Telehealth to provide virtual medical appointments with a primary care or specialty care provider in the RAPPS program.
The enormous promise of virtual care is beginning to be realized in rural Texas. TORCH supports this measure and views telehealth as a gamechanger for access to care in rural, isolated communities…particularly with regard to specialty care services. The sustainability of telehealth for primary care in RHC’s will rely on broadband access and the ability of clinics to be distant site providers. We contend virtual visits should be recognized as face-to-face even after the emergency declaration ends, and primary care is the key to controlling overall health care spend.
6.Advanced use of electronic health record (EHR) in the RAPPS program.
TORCH supports EHR adoption while recognizing some clinics are still trying to automate, or more commonly tried and failed at eliminating paper. We would encourage the commission to consider providing an entry ramp to small, rural clinic providers still endeavoring to deploy electronic health records or advance the systems they have.
7.Care team includes personnel in a care coordination role not requiring clinical licensure in the RAPPS program.
We’re less bullish on the care team structure measure, not because the care team concept lacks merit, but because we don’t project enough allocation per rural health clinic to cover added personnel/staffing costs (or benefits).
8.Please provide any other suggested structure measures for Component 1 and an explanation for its inclusion.
None – we believe two component 1 structure measures are sufficient. If program grows and endures as we hope, we might suggest an eventual revisiting of the electronic health record measure as we approach near universal adoption and a possible shift toward health information exchange (HIE) participation as a component 1 measure.
For Directed Payment Programs, the Centers for Medicare and Medicaid Services (CMS) encourages States to utilize existing, validated, and outcomes-based performance measures to evaluate the payment arrangement, and recommends States use the CMS Adult and Child Core Set Measures.
RAPPS – Component 2 Measures for Year 1
Please provide feedback on the specifications for the following Component 2 measures and their inclusion in the RAPPS program. Refer to the RAPPS Specifications Excel file for additional details. The specifications file is located at DSRIP Transition Website https://hhs.texas.gov/laws-regulations/policiesrules/waivers/medicaid-1115-waiver/dsrip-transition under Transition Milestone Updates.
Component 2 measures require semi-annual reporting. Year 1 Component 2 reporting is tentatively planned to take place during Quarter 1 (September-November 2021) and Quarter 3 (March-May 2022).
All measures must be reported to be eligible for payment.
9.R2-104. Comprehensive Diabetes Care: Hemoglobin A1c (HbA1c) testing Percentage of patients ages 18 to 75 with diabetes (type 1 and type 2) who had a hemoglobin A1c (HbA1c) test.
TORCH supports this measure and understands the enormous cost saving opportunity tied to upstream interventions specific to diabetes care. We also appreciate the continuity provided to rural health clinics who are familiar with this measure – many have likely been reporting in related DSRIP projects.
10.R2-105. Preventive Care and Screening: Influenza Immunization Percentage of patients aged 6 months and older seen for a visit between October 1 and March 31 who received an influenza immunization OR who reported previous receipt of an influenza immunization.
TORCH supports this measure as we’ve been reminded recently of the importance of vaccines. Preventive care and screening are how we avoid hospitalizations and control cost. We also appreciate the continuity provided to rural health clinics who are familiar with this measure – many have likely been reporting in related DSRIP projects.
11.Please provide any other suggested measures for Component 2 and an explanation supporting its inclusion.
None – component 2 measures are appropriate.
For Directed Payment Programs, CMS encourages States to utilize existing, validated, and outcomes-based performance measures to evaluate the payment arrangement, and recommends States use the CMS Adult and Child Core Set Measures.
RAPPS – Attribution Methodology
Using a retrospective attribution methodology, the RAPPS attributed population includes the individuals that a participating Rural Health Clinic (RHC), as approved in the enrollment application, is accountable for under the RAPPS program, as defined by the Attributed Population Inclusion Criteria.
The RHC’s attributed population includes any individual that meets the criterion below:
One encounter with the RHC during the measurement period
The measure-specific denominator population includes the individuals or encounters from the RAPPS attributed population (Step 1) that meet the “Eligible Physician Specialties/Clinicians for Outpatient Measures” criteria and “Denominator Inclusions” and “Denominator Exclusions” criteria for each quality measure as defined in the RAPPS Measure Specifications.
12.Please provide feedback on the proposed RAPPS attribution methodology
Attribution methodology is good.
RAPPS – Quality Requirements for Year 1
The following requirements are for Year 1 of the RAPPS program only. Requirements for Year 2 and Year 3 have not been determined yet.
Measures in Components 2 are identified as Improvement Over Self (IOS) measures or Benchmark Measures.
13.Improvement Over Self Measures
Improvement over self (IOS) seems appropriate. To the extent possible, we would recommend a statewide aggregation of IOS measures to encourage collaboration and avoid individual clinic winners and losers in the program.
Improvement over self (IOS) measures do not have national benchmark data available. For Year 1, IOS measures are reporting CY2021 as baseline as a condition of participation in the program. IOS measures will be pay-for-performance in later years. Please provide feedback on the IOS measure performance requirement of reporting baseline.
14.Benchmark Measures
Benchmark measures have national Healthcare Effectiveness Data and Information Set (HEDIS) benchmark data available. Baselines are not needed for benchmark measures.
Year 1 goals for benchmark measures are meeting or exceeding the 50th percentile of national HEDIS benchmarks for Component 2.
Please provide feedback on the goals for benchmark measure for Component 2
If benchmark measure is applied, we feel strongly that 50% threshold is too high and would effectively block half of potential program participants (the half that need support or incentive). 25% of national benchmark target (or lower) would be better to encourage participation and statewide momentum.
15.Minimum Denominator Volume
If a Component 2 measure does not have a minimum denominator volume of 30 Medicaid Managed Care achievement population cases, then the measure is not included in calculating achievement.
Please provide feedback on the minimum denominator volume requirement for Component 2.
30 case floor in each reporting period is appropriate.
16.Reporting Requirements
During Quarter 1, RHCs must report progress on Component 1 measures and report data for all Component 2 measures for January to June 2021.
During Quarter 3, RHCs report progress on Component 1 measures and report data for all Component 2 measures for January to December 2021.
RHCs must report Medicaid managed care stratified by program population (i.e. STAR, STAR+PLUS, STAR Kids,) as well as Other Medicaid, Uninsured, and Other payer types.
Please provide feedback on the reporting requirements for Component 2.
TORCH supports reporting requirement timing as DSRIP participants are accustomed to the twice annual reporting cadence. We would suggest alignment with other directed payment programs’ reporting requirements to increase familiarity and consolidate deadlines (reporting season).
RAPPS – Component 2 Targeted CPT Codes
A uniform percent rate increase will be applied to certain services based on achievement of quality metrics focused on preventive care and screening and management of chronic conditions.
Component 2 uniform percentage increase will be paid to participating RHCs based on All-Inclusive Clinic Visit T1015 and Office Visits codes including:
99201
99202
99203
99204
99205
99211
99212
99213
99214
99215
99244
99381
99382
99383
99384
99385
99386
99391
99392
99393
99394
99395
99396
99429
G0444
T1015
17.Please provide feedback on the targeted codes (CPT codes and a T code) for Component 2.
None
RAPPS – Additional Comments
18.Please enter any additional comments related to RAPPS quality measures or performance requirements not addressed in other sections.
Reaffirm commitment to support the program and encourage RHC participation.
Hope to find ways to grow the program size by adding services like telemedicine and OB. Appreciate abbreviated measure set to simplify and limit administrative burden for small, rural clinics.
Reemphasize the 50% benchmark measure threshold is just too high in the beginning.
Please submit any questions related to the proposed measures and specifications to: txhealthcaretransformation@hhsc.state.tx.us