Over the past decade, the federal government has started to reimburse for health care through a value-based payment structure. This shift will drive a more financially sustainable, affordable, and efficient system. Unfortunately, health centers have not participated as fully as their capacity and expertise would allow. Policymakers can and should prioritize these safety net providers, both due to the size of the population served and their ability to drive the “value” in value-based care.
CHCs and federal payers should focus on a population health approach that rewards value, not volume. Under both the Medicare and Medicaid programs, policymakers should allow CHCsto move from encounter-based care to enrollment-based care, while allowing CHCs to phase in the adjustment.
CHCs engaging in successful VBC should not be penalized by any new federal or state policy.
VBC at CHCs should facilitate team-based care that leverages all providers proven to deliver effective service.
CHCs should have the opportunity to evolve their participation in VBC, with the prospective payment system acting as a floor.
Policy should enable VBC that addresses health-related social needs.
Facilitate and encourage increased risk-sharing in the Medicaid program. CMS should work with states to allow CHCs to take on full risk for Medicaid beneficiaries.
Fund incentives and technical assistance for states seeking to establish, expand, or improve their alternative payment models (APMs) with federally qualified health centers.
Continue to implement value-based care pilots that encourage participation from FQHCs. The Centers for Medicare and Medicaid Innovation (CMMI) has announced multiple models that specifically target FQHCs. CMMI should continue improving and iterating on these pilots for maximum success.
Clarify and improve policy related to MCOs to ensure successful value-based care models with FQHCs. Medicaid should clarify that services that address the social determinants of health can be considered medical costs for purposes of calculating medical loss ratios, and that services provided by FQHCs to address the social determinants of health can be quality-improvement activities.
Create a temporary add-on to the Medicare Prospective Payment System to allow CHCs to make one-time investments to support long-term participation in value based care. CHCs often have one-time capital needs to support new technology, data infrastructure, or external expertise, that can set them on a course of successful value-based care. A six-month, 10% increase to the Medicare PPS could help support this.