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CMS Extends Community Based Transition Program
2012: Issue 5
By: Sarah E. Swank
Last year, CMS introduced the Community Based Care Transition Program (Program), the goals of which are to reduce hospital readmissions, test sustainable funding streams for care transition services, maintain or improve quality of care, and document measureable savings to the Medicare program. Under section 3026 of the Affordable Care Act, CMS was appropriated $500 million in total funding for the Program from 2011 to 2015. The original deadline to apply for program participation [PDF] was March 2012, but CMS recently extended the application period into the summer of 2012. The final deadline for rolling applications is now June 7, 2012.
Eligibility and Deadlines
Eligible hospitals include acute-care hospitals with high readmission rates that partner with community based organizations (CBOs) or CBOs that provide care transition services to improve a patient’s transition from a hospital to another setting, such as a long-term care facility or the patient’s home. CMS prepared a list of high readmission hospitals [PDF] to determine which hospitals meet this definition for the Program. CBOs will be required to provide care transition services across care settings, which may include at least one of the following:
- Care transition services that begin no later than 24 hours prior to discharge
- Timely, culturally and linguistically competent post-discharge education so patients understand potential additional health problems or a deteriorating condition
- Timely interactions between patients and post-acute and outpatient providers
- Patient-centered self-management support and information specific to the beneficiary’s condition
- Comprehensive medication review and management, including —if appropriate— counseling and self-management support
Applicants must explain in their applications how they will align their care transition programs with care transition initiatives by other payers in their communities, such as Medicaid, Medicare Advantage and private payers. Applications also must select targeted populations and specific intervention that will be used to meet the goals of the Program. Applications are reviewed by a panel on a rolling basis. Applications are due and reviewed on the following dates:
| Applications Received by | Application Reviewed by |
| April 5, 2012 | April 26, 2012 |
| April 19, 2012 | May 10, 2012 |
| May 9, 2012 | May 30, 2012 |
| May 21, 2012 | June 11, 2012 |
| June 7, 2012 | June 28, 2012 |
Program Performance Period
The Program will run five years. Program performance begins the first of the month in which the participant initiates services and continues for two years. If performance targets are met, this period may be extended on an annual basis for the remaining years of the program. The first two rounds of participants have already been accepted into the Program.
Program Agreement
Successful applicants must enter into a Program Agreement [PDF] with CMS. CMS may terminate the program at any time for reasons such as:
- Failure to meet performance targets
- Pervasive beneficiary or provider dissatisfaction
- Commitment of Medicare fraud
- Failure to cooperate with CMS contractors
- Aberrant billing patterns
- Failure to attend and actively participate in learning collaboratives
Participants may terminate the Program Agreement by providing 90-days written notice to CMS. Participants will be responsible for all costs related to closing out of the Program. Under the Program Agreement, a participant agrees to provide a security and privacy plan within 30 days of signing, recognizing that not all participants will be covered entities under HIPAA. Any requests for modification to the terms, beyond the terms explicitly stated in the Program Agreement, must be submitted in writing and approved by the CMS project officer prior to implementation and will be by mutual agreement of CMS and the Program participant.
Implementation and Monitoring
CMS contracted with Mathematica Policy Research (MPR) to provide implementation and monitoring support for the Program. MPR is responsible for receiving and validating billing information in the Program. In addition, MPR will receive the Patient Experience Survey responses. MPR will provide each participant with a quarterly monitoring report that will include all of the claims based measures (all-cause readmission rates, emergency department visits, observation stays, mortality, length of stay, and time to physician follow-up). MPR will perform retrospective audits using claims data to ensure that all of the services were provided only to eligible high-risk Medicare fee-for-service beneficiaries and that claims for individual beneficiaries had been submitted no more often than once every 180 days. CMS may recoup payments made in error to a participant.
Payment
Applicants must provide a clear budget proposal, including a per eligible discharge rate reflecting direct costs for care transition services. This payment will be reflected in the agreement between hospitals and CBOs as well as the agreement with CMS.
Evaluation
CMS will contract with an independent evaluator to study the design and implementation of the Program as well to evaluate the outcomes under the Program. Participants are bound under the Program Agreement to cooperate with the organization selected by CMS to be the program evaluator. Participants may be asked by the independent evaluator to provide additional data.
Ober|Kaler's Comments
As with other demonstrations and programs out of the CMS Innovation Center, CMS is testing the payment mechanism to provide coordinated care while improving outcomes and producing cost savings. This Program's focus is similar to other programs and grants on hospital readmissions, including the recently announced grant with a focus on nursing facilities. Those interested in applying should apply early since the CMS Innovation Center will continue to accept applications for the Program as long as funding is available. The Program website will read “solicitation closed” when the funding ceiling is reached and the CMS Innovation Center is no longer reviewing applications. It is anticipating reviewing applications into the first half of 2012.
