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 connect value-based care to the shared goal of health equity.
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.