Value-based Care Principles & Priorities

Advocates for Community Health members are ready to lead the way to a more equitable, holistic approach to care for the underserved, through patient-centered, value-based care.

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—nearly 29 million patients in 2020—and their ability to connect value-based care to the shared goal of health equity.

Our Value-based Care Principles

  • ACH endorses the Health Care Payment Learning and Action Network Alternative Payment Model Framework, which includes several categories of value-based pay: 1) fee for service linked to quality and value; 2) alternative payment build on fee for service architecture; and 3) population-based payment. Health centers should be supported as they evolve their systems within this framework.
  • FQHCs that have engaged in successful value-based care arrangements to date should not be penalized by any new federal or state policy.
  • Value-based care at FQHCs should prioritize health equity, including elimination of health disparities as well as a culture of equity in all health centers. Over the long term, value-based care must include measurements of equity that are tied to payment.
  • Both health centers and federal payers should be focused on a population health approach that rewards value, not volume. The federal government should work to shift health center thinking from encounter-based care to enrollment-based care, while allowing health centers to phase in the adjustment.
  • FQHCs establishing value-based care arrangements should be focused on the needs of their service area, including clinical care and services to address the non-clinical drivers of health.
  • Value-based care at health centers should facilitate team-based care that leverages all types of providers proven to deliver effective service.
  • Health centers should have the opportunity to evolve their participation in value-based care, with the prospective payment system acting as a floor.

Our Value-based Care Policy Priorities

Invest in capacity building for equitable, value-based care at FQHCs.
Rationale: Value-based care should be accessible to all health centers and their patients.
Recommendation: The federal government, through a partnership between CMS and the Health Resources and Services Administration (HRSA), should fund the capacity building that many health centers need to fully implement a successful value-based care model.

Launch a value-based care pilot for FQHCs through the Centers for Medicare and Medicaid Innovation (CMMI).
Rationale: Medicare and Medicaid cover a substantial number of patients under FQHC care, including the dually-eligible population, and could offer a streamlined demonstration option.
Recommendation: Implementation of value-based care in federal payment programs should include pilot testing of value-based Medicare and Medicaid reimbursement at high-capacity health centers, supported by an integrated effort between HRSA and CMS.

The federal Medicaid program should provide incentives and technical assistance to states seeking to establish, expand, or improve their APMs with FQHCs.
Rationale: Many FQHCs around the country have made innovative payment arrangements with states and/or Medicaid Managed Care Organizations; these should be leveraged and tested at the federal level.
Recommendation: ACH should partner with Medicaid to provide a comprehensive look at existing APMs, identify barriers to success and support dissemination of best practices.

The federal Medicaid program should clarify and improve policy related to MCOs to ensure successful value-based care models with FQHCs.
Rationale: Existing Medicaid MCO requirements, such as what is considered a medical cost, can restrict provider contracting.
Recommendation: 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.

Value-based care models including safety net providers must incorporate risk adjustment measures.
Rationale: Social risk factors must be incorporated into risk adjustment models for value-based care in Medicare and Medicaid in order to provide more accurate benchmarks for participants.
Recommendation: In the Medicaid program, CMS should uplift best practices from the APMs in Massachusetts and other states that incorporate measures of social risk factors. In the Medicare program, CMS should continue to develop and test new risk adjustment methodologies through Medicare Advantage and CMMI.

Federal value-based care should incorporate measures of health equity.
Rationale: Design of value-based care programs will have significant influence over the delivery of health care. Therefore, an explicit intention and goal must be set to reduce disparities through payment programs.
Recommendation: Value-based care should reward FQHCs closing health disparities gaps, using measures developed, tested, and validated with Advocates for Community Health members.

Committed to community, with a visionary and innovative approach, our membership is leading the way in shaping the rapidly evolving health care landscape of the future. Learn more about our other policy priorities and our advocacy efforts.
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