Wednesday DSS unveiled their initial plans to evaluate
PCMH +, the new experimental HUSKY shared savings program that just started
January 1st with 160,000 members. HUSKY’s previous experience with
financial risk was a universally
acknowledged failure. Contrary to promises for a meaningful evaluation of
the program before moving another 200,000 members into the program next
January, DSS does not plan to complete the evaluation until two months after
the finalized RFP is released for the second wave of the experiment. In accord
with the department’s principle to Do No Harm and only act in the best
interests of members as required in federal law, advocates urged the state to
ensure quality, access and cost control were not eroded in the first stage that
just began. The advocates
are concerned about the potential for the experimental payment model to
reverse hard-won progress over the last four years that significantly improved
access to care, raised the quality of care, engaged new providers to
participate and saved
at least $471 million. In a July letter advocates wrote, “That
requirement of federal law cannot be met if the agency rushes another 200,000
enrollees into this experiment without first assessing the results of placing
the initial 200,000+ there, and using what it learns to protect all of them.” Beyond that serious
concern, the department’s plans for the evaluation are wholly inadequate. The
plan relies heavily on desk and ACO office reviews of “operational policies and
procedures”, very similar to the inexplicably glowing evaluations of HUSKY MCOs
for years while the program was dramatically failing. It includes no description
of any analysis of underservice, access to care, quality, movement toward PCMH
certification for all primary care practices, adverse selection/cherry picking,
or overspending.
For example, evaluators intend to interview only two members/families of the
program, and then to choose from the handpicked consumers appointed by ACOs to
their advisory committees. Advocates in other states with Medicaid ACOs report
deeply conflicted family members of ACO owners appointed to advisory boards as
“consumers”. CT has a long history of concerns about the independence of
“consumer advocates” appointed to policymaking boards.
In good news, HUSKY’s PCMH (no +)
program continues
its remarkable progress celebrating five years of improving access to care,
quality, consumer satisfaction, provider engagement, and controlling costs.
