Category: Updates

Each year the Centers for Medicare and Medicaid Services (CMS) reviews payment practices and policy changes under fee-for-service, or traditional, Medicare. The CY2024 PFS included important coding and payment changes for services to address health-related social needs (HRSNs) through separate payments for Community Health Integration (CHI), SDOH Risk Assessment, and Principal Illness Navigation (PIN) services.

In July 2024, CMS released its annual draft proposed updates for next year’s rules (CY2025 Medicare Physician Fee Schedule), which includes a request for information (RFI) regarding barriers to implementation for services to address HRSNs. 

The draft rule also includes proposed updates to:

• Caregiver Training Services;
• ACO quality measures re: screening for HRSNs; and
• the Advanced Primary Care Model (APCM)

All of these proposed changes could affect services to address HRSNs. 

On September 9, 20204 the Partnership submitted two letters to CMS on behalf of Partnership Co-Chairs and undersigned organizations. Sixty-five organizations signed on to the response to the request for information (RFI) regarding current barriers to implementing services to address HRSNs (CHI/PIN). Fifty-three organizations signed on to the letter regarding changes needed and proposed updates for telehealth, caregiver training services, ACO quality measures, and the Advanced Primary Care Model. Agency officials will review and document the more than 12,000 comments submitted as they finalize the rule.

Stay tuned for updates once we see the final rule published—likely in early November 2024. We will also be in touch with stakeholders regarding implementation resources that we plan to create and promote
once we see the final rule.

Each year the Centers for Medicare and Medicaid Services (CMS) reviews payment practices and policy changes under fee-for-service, or traditional, Medicare. The CY2024 PFS included important coding and payment changes for services to address health-related social needs (HRSNs) through separate payments for Community Health Integration (CHI), SDOH Risk Assessment, and Principal Illness Navigation (PIN) services.

In July 2024, CMS released its annual draft proposed updates for next year’s rules (CY2025 Medicare Physician Fee Schedule), which includes a request for information (RFI) regarding barriers to implementation for services to address HRSNs. 

The draft rule also includes proposed updates to:

• Caregiver Training Services;
• ACO quality measures re: screening for HRSNs; and
• the Advanced Primary Care Model (APCM)

All of these proposed changes could affect services to address HRSNs. 

SIGN-ON REQUEST:
Please consider joining the Partnership to Align Social Care Co-Chairs and other organizational stakeholders on TWO sign-on letters offering comments. You may sign on to one or both letters: 

1. Sign-on letter responding to the RFI re: barriers to implementing services to address HRSNs
2. Sign-on letter responding changes needed and proposed updates for telehealth, caregiver training services, ACO quality measures, and the Advanced Primary Care Model

We also encourage you to download template language covering all of these issues and incorporate as applicable into your organization's response . As a reminder, comments are due by 5:00 p.m. ET on September 9, 2024, and can be submitted online.  

RESOURCES:

• SIGN-ON Letters (combined) responding to CMS CY2025 PFS Proposed Rule (pdf)
• Template language provided by the Partnership (Word version available for download)
• CMS CY2025 PFS Proposed Rule: https://www.regulations.gov/document/CMS-2024-0256-0045 
• Additional information and resources from the Partnership about this proposed rule: https://www.partnership2asc.org/implementation-resources/ and Resources List

This month’s Gravity Implementation Affinity Group featured Timothy McNeill, RN, MPH from the Partnership to discuss the new calendar year 2024 social needs HCPCS codes. Implementers learned how Gravity SNOMED-CT intervention codes align with and support additional documentation aligned with regulatory and policy drivers.

Thank you to Civitas Networks for Health for your support of the Gravity Implementation Affinity Group meetings.

Our Partnership to Align Social Care co-chair, Timothy McNeill, RN, MPH, spoke at USAging's Aging Policy Briefing with colleagues from around the nation about the 2024 Medicare Physician Fee Schedule and how to implement changes in billing codes to better align care between CBOs, health entities, and Area Agencies on Aging.

Tim was joined by Kelly Cronin, Deputy Administrator, Center for Innovation and Partnership, U.S. Administration for Community Living; Doug Jacobs, MD, MPH, Chief Transformation Officer, Center for Medicare & Medicaid Services; and Christine Vanlandingham, CEO, Region IV AAA in St. Joseph Michigan.

We encourage you to learn more about these changes in the Medicare Physician Fee Schedule here: https://go.cms.gov/4c5f090

Healthcare entities and social services providers are increasingly recognizing the importance of partnerships among historically siloed sectors to address health-related social needs (HRSNs). While the number of community-based organizations (CBOs) and community care hubs (CCHs) pursuing contracting relationships with healthcare organizations is increasing, CBOs and CCHs can experience challenges entering into contracting arrangements with the healthcare sector.

The Partnership to Align Social Care, the Aging and Disability Business Institute, and Camden Coalition created a Healthcare Guide to Contracting with CBOs. This toolkit offers a deep dive into leading contracting practices to effectively and efficiently address HRSNs. Each module focuses on the essential elements of contracting between health care and community partners and features leading practices from the field.

“As one of the nation’s largest providers of Medicaid services, CommonSpirit works with community-based organizations in more than 21 states because we believe it’s critical to the health of the communities we serve,” said

Ji Im, MPH, senior director for community and population health for CommonSpirit and leader of one of the Partnership to Align Social Care’s work groups.     “Through our participation in the Partnership, we are bringing decades of best practices to help create a blueprint for the integration of health care and social services.”

Research shows that aligning health care with organizations that connect people to community resources–childcare, jobs, housing, nutrition, and transportation–measurably improves the overall health of the population and can impact

up to 80 percent of health outcomes.^[1] The Partnership to Align Social Care was established to help create efficient networks that share information, are owned by the community, and supported by all the agencies, institutions, and businesses that are involved in improving health.

“CommonSpirit has been foundational to forming our Partnership and helping define its mission,” said June Simmons, MSW, Partnership to Align Social Careco-chair and Partners in Care Foundation CEO. “As a leader of one of our key workgroups, CommonSpirit is helping to convene diverse stakeholder groups to co-design a model that can be implemented across the country to create healthier communities.”

Founding organizations include health plans such as Aetna CVS Health, Elevance Health, Humana and United Healthcare; integrated delivery networks such as Kaiser Permanente; health systems including CommonSpirit and Rush University Medical Center; community-based organization (CBO) networks including the Detroit Agency on Aging, Partners in Care Foundation, and the Camden Coalition of Healthcare Providers. Liaisons from several federal agencies including the Administration for Community Living (ACL), the Center for Medicare & Medicaid Innovation (CMMI), and the Office of the National Coordinator for Health Information Technology (ONC) advise this effort.

Through the Partnership, organizations that may not typically work together have established a forum to create a framework that will build and sustain the capacity of CBO networks to provide social services. The Partnership will focus on priority issues including:

• Co-designing common standards for effective and sustainable partnerships of CBO networks, health plans, and health systems
• Identifying core attributes and competencies for CBO network credentialing
• Identifying/encouraging widespread use of existing billing codes and essential elements for a streamlined contracting process between health systems, health plans, and CBOs
• Making recommendations for infrastructure capabilities and financing for more sustainable CBO networks

CommonSpirit’s participation in the Partnership leverages its work in initiating and advancing models to close the gap between medical and non-medical providers and create a continuum of care so that patients receive the services they need to reach their greatest health potential. These include the Connected Community Network (CCN) model, which has been implemented in more than 20 different markets, to bring together diverse stakeholders to create an infrastructure for connecting underserved populations with the community resources they need. CCNs include shared governance and an innovative “community bank” concept, which creates a sustainable funding mechanism: funding partners contribute to the community bank and share in community infrastructure costs. Similarly, CommonSpirit has partnered with Pathways Community HUB Institute (PCHI) on a collaborative, outcome-based payment model for community health workers that complements the CCN and involves many of the same types of organizations and institutions.

About CommonSpirit Health
CommonSpirit Health is a nonprofit, Catholic health system dedicated to advancing health for all people. It was created in February 2019 by Catholic Health Initiatives and Dignity Health. With its national office in Chicago and a team of over 150,000 employees and 25,000 physicians and advanced practice clinicians, CommonSpirit operates 140 hospitals and more than 1,500 care sites across 21 states. In FY 2021, CommonSpirit had revenues of $33.3 billion and provided $5.1 billion in charity care, community benefit, and unreimbursed government programs. Learn more at www.commonspirit.org.

About Partnership to Align Social Care

The Partnership to Align Social Care—A National Learning and Action Network (Partnership), is a unique collective commitment to achieve meaningful alignment of health care and social care systems. The Partnership includes leaders among community-based organizations, health plans and systems, national associations and advocacy organizations, philanthropic organizations, foundation, academic institutions, federal agencies, and other key participants collaborating to co-design a strategy to enable successful partnerships between health care organizations and networks of community-based organizations (CBOs) delivering social care services delivering health-impacting social care. The Partnership aims to align with the CMS Innovation Center Strategy Refresh and aspires to support health and social care delivery system transformation that enables value-based care. Core components include shared governance, sustainable financing, multi-stakeholder accountability, and policy changes at the federal, state, and local levels. Learn more at www.partnership2asc.org.

^[1] https://www.rwjf.org/en/library/research/2019/02/medicaid-s-role-in-addressing-social-determinants-of-health.html

Members of the Partnership are collaborating to co-design a plan to build the full capacity of community based organizations (CBOs) to deliver health-impacting social care.The Partners in Care Foundation has received a one-year, $350,000 award from the Robert Wood Johnson Foundation to support a multi-disciplinary group known as the Partnership to Align Social Care – A National Learning and Action Network (Partnership).

Members of the Partnership are collaborating to co-design a plan to build the full capacity of communitybased organizations (CBOs) to deliver health-impacting social care.

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