Significant questions have been raised about the methodology
and sources for the Sept.
17th SIM presentation (slide 30) asserting that 62% of primary
care providers in CT currently have provider risk/shared savings/total cost of
care arrangements with providers. Questions relate to whether the populations
included are representative of the state, provider types included, whether the
number relies on one payer disproportionately, and the possibility of double
counting among other issues.
Unfortunately this questionable number is being used as the
foundation of a proposal that may undermine even the minimal quality standards
in the current SIM proposal. Last week, in a private email, SIM steering committee
members were asked for input on whether, given the perceived prevalence of
provider risk, SIM should propose allowing provider incentives even in the
absence of medical home status. Presumably this is to avoid jeopardizing the primary
SIM goal of moving at least 80% of state residents into provider risk
arrangements, regardless of quality protections. Advocates
have called on SIM leaders to build a robust quality monitoring system
before any provider incentives are implemented. Advocates are hoping to both improve
the quality of care in CT and prevent the harm to people that occurred in
managed care risk arrangements in the past.
The current SIM medical home plan is to create a
CT-specific, lower standard than the commonly-used, well-vetted national
accrediting bodies. (They have taken “person/patient-centered” out of the label
for their lower standard.) There are currently 821 NCQA certified PCMHs in CT
and the list grows every month. One third of Medicaid consumers are now cared
for in a PCMH. It is important to note that a large proportion of Medicaid
providers, with lower payment levels, have earned PCMH designation.