Vermont Medicaid Next Generation Pilot Program 2017 Performance

Similar documents
In accordance with Act 124 of 2018 (H.914)

Presentation by Kevin Stone Senior Consultant and Principal Helms & Company Concord NH

GMCB Update Health Reform Oversight Committee. Chair Kevin Mullin and Michael Barber October 25, 2018

RFP MEDICAID SHARED SAVINGS PROGRAM FOR ACCOUNTABLE CARE ORGANIZATIONS 10/25/

Adopting Multi-Payer and All- Payer Payment Models in States OCTOBER 25, 2016 WASHINGTON MARRIOTT WARDMAN PARK HOTEL WASHINGTON, DC

Vermont Legislative Joint Fiscal Office

Advancing Risk Capability in 2015: Medicare Shared Savings Program and ACO Investment Model. March 23, 2015 // 12:00 P.M. 1:00 P.M.

Coverage Expansion [Sections 310, 323, 324, 341, 342, 343, 344, and 1701]

CPC+ PAYMENT METHODOLOGIES: BENEFICIARY ATTRIBUTION, CARE MANAGEMENT FEE, PERFORMANCE-BASED INCENTIVE PAYMENT, AND PAYMENT UNDER THE MEDICARE


HIT Fund Balance Since SFY 2009

No change from proposed rule. healthcare providers and suppliers of services (e.g.,

North Carolina Medical Society 2015 Medicaid Reform Analysis Updated 07/15/15

MEDICARE-MEDICAID CAPITATED FINANCIAL ALIGNMENT MODEL QUALITY WITHHOLD TECHNICAL NOTES (DY 2 5)

Next Generation Accountable Care Organization (ACO) Model Overview

79th OREGON LEGISLATIVE ASSEMBLY Regular Session. Enrolled. Senate Bill 934 CHAPTER... AN ACT

JOINT TASK FORCE ON HEALTH CARE COST REVIEW (Senate Bill 419)

Sent via electronic transmission to:

10/17/2014 Risk-Based Payment Methodologies A National Perspective Art Jones, MD. AccountableCareInstitute.com

CURRENT DEVELOPMENTS IN VALUE BASED PAYMENT (VBP): Part 1 Recent Initiatives

CHCS. Technical Assistance. Tool. Implementing the Medicaid Primary Care Rate. Increase: A Roadmap for States. Center for Health Care Strategies, Inc.

July 27, 2018 Emergency Board Meeting Report on Medicaid for Fiscal Year 2018

Delivery System Reform Incentive Payment (DSRIP) Program Extension Planning and Protocols

UnityPoint Accountable Care Aligning Provider Incentives in Risk- Bearing, Value-Based Contracts. March 10, 2018

Rewarding High Quality: Practical Models for Value- Based Physician Payment

The 2018 Advance Notice and Draft Call Letter for Medicare Advantage

kaiser commission on O L I C Y R I E F P H O N E: (202) , F A X: ( 202)

Oklahoma Health Care Authority

Centers for Medicare & Medicaid Services Center for Medicare and Medicaid Innovation Seamless Care Models Group 7205 Windsor Blvd Baltimore, MD 21244

No An act relating to health care financing and universal access to health care in Vermont. (S.88)

Centers for Medicare & Medicaid Services Center for Medicare and Medicaid Innovation Seamless Care Models Group 7205 Windsor Blvd Baltimore, MD 21244

THE $10,000 QUESTION: TACKLING THE COMPLEXITIES OF VALUE-BASED PHYSICIAN COMPENSATION

CMS Quality Payment Program

The ACO Effort: A Status Report

Final Policy, Payment, and Quality Provisions in the Medicare Physician Fee Schedule for Calendar Year 2018

Clinic Comparison Reporting. June 30, 2016

Centers for Medicare & Medicaid Services: Innovation Center New Direction Request For Information: Medicare Advantage (MA) Innovation Models

Department of Vermont Health Access. Cory Gustafson Commissioner

Request for Applications

FACT SHEET. November 1, *See the HIMSS ACO Final Rule Executive Summary for more details on the One-Sided and Two-Sided Payment Models

CMS 1701 P UnityPoint Health. October 16, 2018

Issue brief: Medicaid managed care final rule

FAQs: Accountable Care Organizations (ACOs)

C - Suite Transformation Management Training: Finance and Operations Overview. May 17, 2017

Health Industry Forum Key Policy Issues in the Evolution of Medicare ACO Programs

Mike Cheek, Senior Vice President, Reimbursement Policy & Legal Affairs. David Gifford, Senior Vice President, Quality and Regulatory Affairs

Savings Impact of Community Care of North Carolina: A Review of the Evidence

INFORMATION ABOUT YOUR OXFORD COVERAGE

CRP Value Base Pilot: An Update

Opportunities on the Horizon. CCWJC/CCPN Provider Meeting Update November 2 nd, 2017

Section H.202 As Introduced H.202 As Passed the House Changed name of Vermont Health Reform Board to Green Mountain Care Board

May 23, The Honorable Orrin Hatch Chairman Senate Finance Committee 219 Dirksen Building Washington, D.C Dear Chairman Hatch:

Medicare Accountable Care Organizations What & Why?

Centers for Medicare & Medicaid Services Center for Medicare and Medicaid Innovation Seamless Care Models Group 7205 Windsor Blvd Baltimore, MD 21244

Figure 1: Original APM Framework

Medicare Comprehensive ESRD Care (CEC) Initiative

Clinical Integration:

Alabama Medicaid. APHCA Compliance Academy and Networking Forum. May 24, 2018

Presentation to the IOM Committee on Core Metrics Tom Williams, Dr PH, President & CEO, IHA January 7, 2014, Irvine, California

March 1, Dear Mr. Kouzoukas:

All Payer Hospital System Modernization Payment Models Workgroup. Meeting Agenda

STARs Program and SETMA s Solution By James L. Holly, MD Your Life Your Health The Examiner April 26, 2012

Proposed Changes to the Medicare Shared Savings Program for Accountable Care Organizations

Title: The Comprehensive Primary Care Initiative: Another Side of the Story All Payer Aggregate Results

Developing Your Value Proposition. Timothy P. McNeill, RN, MPH

Iowa Medicaid Synopsis of Managed Medicaid Request for Proposal

COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE HARRISBURG, PENNSYLVANIA

Calculating Savings in the New Jersey Medicaid Accountable Care Organization Demonstration Program

Avalere Health 2015 Industry Outlook

The 2011 Legislative Session: Implementation of the federal Affordable Care Act (ACA) and Vermont s Health Care Reform Initiatives November 8, 2010

FUNDS FLOW METHODOLOGY FOR RISK-BASED CONTRACTS

Cal MediConnect CY 2014 Rate Report

September 6, Re: CMS-1600-P; CY 2014 Physician Fee Schedule Proposed rule comments

Ohio Joint Medicaid Oversight Committee State Fiscal Years Biennium Growth Rate Projections

Performance Measurement Work Group Meeting 01/17/2018

Deep Dive Medicare Advantage Advance Notices Part I and II

Monitoring Maryland Performance Financial Data. Year to Date thru April 2015

Integrated Health Partnerships Demonstration

Draft Recommendations on the Update Factors for FY 2017

Financing Oral Health Care for Medicaid and CHIP Beneficiaries: What States are Doing

9/23/2016. Our Services. Transitioning from Fee-for-Service to Value-based Reimbursement. Key Trends and Strategies for Rural Health Providers

A Guide to Submitting Medicaid Requests for Other Payer Advanced APM Determinations (Payer Initiated Submission Form)

Health Plan and Provider Collaboration Really?

CMS PROPOSES KEY PROVISIONS OF MACRA PHYSICIAN PAYMENT SYSTEM FOR 2019

Medicare Advantage Value-Based Insurance Design: Considerations and implications

Medicare Advantage Value-Based Insurance Design Model Test. Responses to Stakeholder Inquiries. Last updated: November 10, 2015

Medicare Shared Savings Program: Accountable Care Organizations final rule

Regarding Implementation of ACT 158:

Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program

McKinney s Public Health Law 2999-n n. Accountable care organizations; findings; purpose. Effective: October 3, 2012

Provisions of the Medicare Modernization Act

Value-Based Payment Reform Academy: What to Consider when Designing a Risk Adjustment Strategy for Value-based APMs for FQHCs

Medicare-Medicaid Alignment Initiative CY 2015 Final Rate Report March 20, 2015

Risk Adjusted Episodes as Benchmarks for ACOs: A Society of Actuaries Sponsored Study

Federally Qualified Health Center / Rural Health Clinic Prospective Payment System Plus Reimbursement Methodology

Medicare Accountable Care Organization Track 1+ Model. March 22, 2017

All About APMs: What Will It Take for Physicians to Earn the APM Bonus Under MACRA?

Submitted via Federal e-rule making Portal: April 5, 2019

Center for Medicare & Medicaid Services (CMS) Medicaid and CHIP Managed Care Final Rule (CMS 2390-F) Fact Sheet: Subpart B State Responsibilities

Ch. 358, Art. 4 LAWS of MINNESOTA for

Transcription:

State of Vermont Department of Vermont Health Access NOB 1 South, 1 st Floor 280 State Drive Waterbury, Vermont 05671 REPORT TO THE GENERAL ASSEMBLY Vermont Medicaid Next Generation Pilot Program 2017 Performance Submitted to House Committee on Appropriations House Committee on Human Services House Committee on Health Care Senate Committee on Appropriations Senate Committee on Health and Welfare Health Reform Oversight Committee Green Mountain Care Board Office of the Health Care Advocate Medicaid and Exchange Advisory Board Submitted by Cory Gustafson, Commissioner Department of Vermont Health Access Michael Costa, Deputy Commissioner Department of Vermont Health Access September 20, 2018

This report is submitted as a supplement to the quarterly reports required by Act 124 of 2018, An Act Relating to Reporting Requirements for the Second Year of the Vermont Medicaid Next Generation ACO Pilot Project. 1 The report summarizes pilot project performance in 2017 and proceeds in three sections. Section A offers an executive summary. Section B provides a brief overview of the program. Section C summarizes financial and quality performance for the 2017 performance year. Section A: Executive Summary of Vermont Medicaid Next Generation 2017 Results The Vermont Medicaid Next Generation (VMNG) Accountable Care Organization (ACO) Pilot program represents Medicaid s participation in the integrated health care system envisioned by the Vermont All- Payer Accountable Care Organization Model agreement with the Centers for Medicare and Medicaid Services (CMS). The Department of Vermont Health Access (DVHA) contracts with an ACO, OneCare Vermont, to pre-pay for the cost of care for a group of Medicaid beneficiaries for a calendar year. OneCare and its network of providers agree to focus on increasing the quality of care and moderating the cost of care for these Vermonters. Additionally, OneCare accepts financial risk if program costs exceed the agreed upon price up to a capped amount of 3% of total price. DVHA makes a fixed prospective payment to OneCare monthly for some of the predetermined amount and pays the rest of the dollars on OneCare s behalf through fee-for-service payments to health care providers both in and out of OneCare s network (see Figure 1). The 2017 program results indicate sufficient, incremental progress that warrants cautious optimism and a continued commitment to the program. Figure 1. Agreed Upon Price for Care, 2017 VMNG Contract $90,000,000 $80,000,000 $70,000,000 $60,000,000 $50,000,000 $40,000,000 $30,000,000 $20,000,000 $10,000,000 $- $29,336,803 $52,659,844 Portion allocated for prospective payment Portion allocated for FFS payment Result 1: DVHA and One Care launched the program successfully. In 2016, DVHA issued a Request for Proposals (RFP) for a new ACO program based on Medicare s Next Generation ACO Program. OneCare Vermont was selected as the Apparently Successful Bidder. DVHA conducted a readiness review prior to the launch of the 2017 program year. OneCare Vermont satisfied the majority of requirements before January 1, 2017 and completed all outstanding Readiness Review items prior to the end of the first quarter of 2017. 1 See https://legislature.vermont.gov/assets/documents/2018/docs/acts/act124/act124%20as%20enacted.pdf. 1

DVHA worked with DXC Technologies to change Medicaid payment systems to make fixed prospective payments to OneCare Vermont. Processes for ongoing data exchange between DVHA and OneCare have been implemented and are regularly evaluated for potential improvements. DVHA and OneCare prepare and maintain an operational timeline to ensure contractually required data sharing and reporting occurs in a timely manner. OneCare and DVHA have established a forum for convening operational teams on a weekly basis, and for convening subject matter experts monthly. These forums have allowed the teams to identify, discuss, and resolve multiple operational challenges, and have resulted in several process improvements to date. DVHA and OneCare have worked together to monitor and report on program performance on a quarterly basis. Result 2: The program is growing. Additional providers and communities have joined the ACO network to participate in the program for the 2018 performance year, and more are expected to do so for the 2019 performance year. 2017 Performance Year 2018 Performance Year 2019 Performance Year Hospital Service Areas 4 10 13 Hospitals, FQHCs, Hospitals, FQHCs, Hospitals, FQHCs, Provider Entities Independent Practices, Independent Practices, Independent Practices, Home Health Providers, Home Health Providers, Home Health Providers, SNFs, DAs, SSAs SNFs, DAs, SSAs SNFs, DAs, SSAs Unique Medicaid Providers ~2,000 ~3,400 ~4,300 Result 3: The ACO program spent less than expected on health care in 2017. DVHA and the ACO agreed on the price of health care upfront, and the ACO spent approximately $2.4 million less than the expected price (see Figure 2). Financial performance was within the ±3% risk corridor, which means that OneCare Vermont and its members are entitled to save those dollars. Result 4: The ACO met most of its quality targets. The ACO s quality score was 85% on 10 pre-selected measures. Notably, OneCare s performance exceeded the national 75 th percentile on measures relating to diabetes control and engagement with alcohol and drug dependence treatment. Examining quality trends over time will be important in order to understand the impact of changing provider payment on quality of care. 2

% ETCOC Figure 2. 2017 VMNG Financial Performance within Expected Total Cost of Care $90,000,000 110% $80,000,000 $2,365,825 ±3% Risk Corridor 100% 90% $70,000,000 $26,970,978 80% $60,000,000 70% $50,000,000 60% $40,000,000 $30,000,000 Expected Total Cost of Care Actual Total Cost of Care 50% 40% $52,659,844 30% $20,000,000 20% $10,000,000 10% $- 0% Paid Prospectively Paid FFS Portion allocated for FFS payments but not paid (costs avoided) Result 5: DVHA is seeing more use of primary care among ACO-attributed Medicaid members. Based on preliminary analyses of utilization, the cohort of attributed members has had higher utilization of primary care office-visits than the cohort of members who are eligible for attribution but not attributed (see Figure 3). As further information about utilization becomes available, DVHA will conduct 3

more robust analyses to determine whether differences between cohorts are statistically significant, and to understand the impact of the program on utilization patterns over time. Figure 3. Primary Care Visits Per 1,000 Member Years by Age and Year 5,000 4,500 4,000 3,500 3,000 2,500 2,000 1,500 1,000 500 0 0-17, 2015 0-17, 2016 0-17, 2017 18+, 2015 18+, 2016 18+, 2017 Attributed Non-Attributed 4

Section B: Vermont Medicaid Next Generation ACO Pilot Program Overview Introduction The Vermont Medicaid Next Generation (VMNG) Accountable Care Organization (ACO) Pilot program represents the initial phase of Medicaid s participation in the integrated health care system envisioned by the Vermont All-Payer Accountable Care Organization Model agreement with the Centers for Medicare and Medicaid Services (CMS). 2 ACOs are provider-led and -governed organizations, with a substantial regional clinical leadership role, that have agreed to assume accountability for the quality, cost, and experience of care. The model s goal is an integrated health care system that has aligned incentives to improve quality and reduce unnecessary costs. The VMNG ACO Pilot program pursues this goal by taking the next step in transitioning the health care revenue model from Fee-for-Service payments to Value-Based payments. This transition is meant to focus health care payments on rewarding value, meaning low cost and high quality, rather than volume of services provided. The VMNG program allows the Department of Vermont Health Access (DVHA) to partner with a riskbearing ACO. For Calendar Year 2017, DVHA contracted with OneCare Vermont (OneCare) ACO to manage the quality and cost of care for approximately 29,000 Medicaid members in four communities. Together, DVHA and OneCare are piloting a financial model designed to support and empower the clinical and operational capabilities of the ACO provider network in support of the Triple Aim of better care, better health, and lower costs. Primary goals of the program are to increase provider flexibility and support health care professionals to deliver the care they know to be most effective in promoting and managing the health of the population they serve. This will contribute to improving the health of Vermonters and moderating health care spending growth in future. OneCare Vermont ACO Network & Attribution In February of 2017, DVHA contracted with OneCare to participate in the Vermont Medicaid Next Generation ACO Pilot program for the 2017 calendar year with four optional one-year extensions. 3 In 2017, OneCare Vermont s network of participating providers included the University of Vermont Medical Center, Central Vermont Medical Center, Northwestern Medical Center, and Porter Hospital along with their employed physicians and providers; two Federally Qualified Health Centers; independent practices; home health providers; Designated Agencies; Area Agencies on Aging; and skilled nursing agencies in the four participating communities. Attribution is primarily based on a Medicaid member s relationship with a primary care provider who has elected to participate in the ACO network. Attribution of Medicaid members to the ACO occurs prospectively, at the start of the program year. In this way, the ACO is aware of the full population for which it is accountable at the program s outset and can use that information to identify and engage members most effectively. Although no members can be added during the course of a program year, some of the prospectively attributed members may become ineligible for attribution during the course of the program year. Members may become ineligible for attribution due to: 2 See http://gmcboard.vermont.gov/sites/gmcb/files/documents/10-27-16-vermont-all-payer-accountable-careorganization-model-agreement.pdf. 3 See http://dvha.vermont.gov/administration/onecare-aco-32318-final-searchable.pdf. 5

Becoming ineligible for Medicaid coverage 4 Switching to a limited Medicaid benefits package (e.g. pharmacy-only benefits) Gaining additional sources of insurance coverage (e.g. commercial or Medicare) Death Financial Model Through the VMNG, DVHA pays OneCare a monthly fixed prospective payment (FPP) for services provided by hospitals (and hospital-owned practices) participating with the ACO. This is a monthly, per member payment made in advance of the services being performed. Medicaid fee-for-service payments continue for all other non-hospital providers in the ACO, for all providers who are not a part of the ACO, and for all services that are not included in the fixed prospective payment. The ACO is responsible for both the cost and quality of care for each attributed member. This is true whether that person uses little or no care or whether they require services consistently throughout the year. One of the key goals of the prospective payment model is to give providers and Medicaid certainty and predictability regarding revenue for a pre-identified population of Vermonters. This should lead to better incentives and provider investments that improve the quality of care for Vermonters. The ACO has agreed to a risk-based spending target for the full attributed population during the performance year. If the ACO exceeds its spending target for the Performance Year, it is liable for expenses up to 103% of the target; if the ACO spends less than its target, it may retain savings to 97% of the target. This arrangement provides an incentive to use resources efficiently. The ACO also withheld some of the payment to providers up front 0.5% in 2017 to support a quality incentive program. The providers in the ACO can earn this money back through high quality performance on targeted quality measures. This type of payment incentive is provided to encourage high quality care and is expected to grow over time. 2017 Performance Overview Since executing the Vermont Medicaid Next Generation contract in February of 2017, DVHA and OneCare Vermont collaborated in the launch and ongoing implementation of the pilot program. OneCare, its network of providers, and DVHA demonstrated the ability to stand up the VMNG ACO pilot program in 2017, including: Operationalizing fixed prospective payments from Medicaid to an ACO and switching to predictable and reliable revenue stream for participating hospitals. Operationalizing a waiver of prior authorization for providers participating in the VMNG program to address provider administrative burden. Developing and refining approaches to financial monitoring and reporting to understand program performance. DVHA and OneCare are committed to ongoing improvement in implementation of the program and in evaluating performance. The two organizations have been able to use 2017 experience to identify opportunities and develop strategies for continual process improvement as the program evolves and includes more providers and Medicaid beneficiaries over time. 4 If a member has lost Medicaid coverage but later becomes eligible for Medicaid again during the performance year, they may also become eligible for attribution again at that time. 6

Overall, the focus of the ACO program is on improving health and delivering high quality health care while creating a financial model capable of producing predictable and sustainable health care costs. DVHA will continue to analyze the operational, financial, and quality performance of the program to determine its efficacy and to determine whether the ACO program generally, and the fixed prospective payments to hospitals specifically, are contributing to an overall moderation in DVHA health care spending. 2017 program year results alone are insufficient to evaluate the success of the model, but the experience from the first year of VMNG implementation has provided a foundation for continued implementation and evaluation. 7

Section C: Vermont Medicaid Next Generation ACO Financial and Quality Performance: January 1 December 31, 2017 Financial Performance Table 1 sets forth ACO financial performance in Calendar Year 2017. The table includes several components: Funds paid prospectively to OneCare by DVHA (paid on a monthly basis). Zero-paid shadow claims that are submitted by providers, used to understand what services were delivered and to calculate the cost of services delivered (according to the Medicaid feefor-service fee schedule) that were covered by the prospective payment from DVHA to OneCare. Fee-for-service claims paid by DVHA on behalf of OneCare (claims for services received by Medicaid members attributed to the ACO from providers in the ACO network who have elected to continue to be reimbursed on a fee-for-service basis, and from providers outside the ACO network). Adjustments made to the Expected Total Cost of Care as part of the year-end reconciliation process. Overall, actual expenditures for the program in 2017 are compared to expected expenditure as an indicator of financial performance. The Expected Total Cost of Care is derived based on actuarial projections of the cost of care in 2017 for the population of prospectively attributed Medicaid members, as detailed in Attachment B of the 2017 VMNG program contract. 5 OneCare s actual expenditure in 2017 was lower than the expected expenditure for the attributed population in the program year. This is true with respect to both the fee-for-service payments that DVHA issues on OneCare s behalf and the prospective payments made by DVHA to OneCare zero-paid shadow claims for services included in the prospective payment total to less than the expected amount. This is consistent with the intent of the incentives of the payment model, and results in a smaller loss against the true delivery expense to deliver the services. This will help ensure provider commitment to the predictable model, and improvements in access and quality for Medicaid enrollees. Final financial performance for the 2017 calendar year was 97.11% of the Expected Total Cost of Care, which is within the ±3% risk corridor included in the 2017 contract. As such, OneCare Vermont is entitled to retain the savings between the Actual Total Cost of Care and the Expected Total Cost of Care, totaling approximately $2.4 million for the 2017 performance year. 5 DVHA engaged Wakely Consulting Group to calculate 2017 ACO rates, including the Expected Total Cost of Care. These rates were also reviewed by OneCare and the Green Mountain Care Board, and by the actuarial firms with which they contracted at the time (Milliman and Lewis & Ellis, respectively). 8

Table 1. Overview of VMNG Financial Performance, 2017 DVHA Payment to ACO $ 50,651,871.21 (A) (B) + (C) + (D) + (E) + (F) Fixed Prospective Payment (FPP) $ 47,435,653.23 (B) Quality Withhold $ 412,059.98 (C) Primary Care Case Management (PCCM) Fee $ 726,387.50 (D) Care Coordination Payment (CCP) $ 1,038,885.25 (E) Administrative Fee $ 1,038,885.25 (F) Total ACO Payments to Providers $ 49,200,925.98 (G) (B) + (D) + (E) Total Expected Shadow FFS $ 52,659,843.59 (H) Total Actual Shadow FFS $ 44,531,294.27 (I) Shadow FFS Over (Under) Spend $ (8,128,549.32) (J) (I) (H) Total Expected FFS $ 29,659,883.84 (K) Actual FFS - In Network $ 5,617,338.69 (L) Actual FFS - Out of Network $ 21,353,639.38 (M) Total Actual FFS $ 26,970,978.07 (N) (L) + (M) FFS Over (Under) Spend $ (2,688,905.77) (O) (N) (K) Expected Total Cost of Care $ 82,319,727.43 (P) (H) + (K) Actual Total Cost of Care $ 79,630,821.66 (Q) (H) + (N) Total Cost of Care Over (Under) Spend $ (2,688,905.77) (R) [(H) + (N)] [(H) + (K)] Adjust ETCOC Downward for MEG Adjustments* $ 276,945.36 (S) Adjust ETCOC Downward for AIPBP Payments Made for Months when Member was No Longer Eligible for Medicaid^ $ 46,135.32 (T) Total ETCOC Reduction $ 323,080.68 (U) (S) + (T) Adjusted Expected Total Cost of Care $ 81,996,646.75 (V) (P) (U) Actual Total Cost of Care $ 79,630,821.66 (Q) Adjusted Total Cost of Care Over (Under) Spend $ (2,365,825.09) (W) (Q) (V) *Medicaid Eligibility Group (MEG) adjustments are required in instances where DVHA paid a prospective payment for an attributed member according to a MEG assignment that was not current for that month. For example, if a payment was issued to OneCare for a General Child, but the attributed member had aged into the General Adult group, an adjustment would be made to the Expected Total Cost of Care for the difference. ^Adjustments are also required when DVHA paid a prospective payment for a member who was no longer Medicaid eligible. For instance, if a payment was issued to OneCare for a member who had passed away, the Expected Total Cost of Care would be adjusted downward and any dollars paid to OneCare for that month would be recouped. 9

Quality Performance The VMNG ACO contract includes measures that are used to evaluate the quality of care for the population of attributed Medicaid members. ACO-level quality is evaluated based on performance on 10 measures that impact payment. In addition to payment measures, the 2017 contract also included two reporting measures; performance on these measures does not impact payment. Table 2 sets forth ACO financial performance in Calendar Year 2017. The table includes several components: Measure name and National Quality Forum (NQF) number (or other number if the measure is not currently endorsed by the NQF); Measure numerator (the number of attributed members meeting the criteria for the measure), denominator (the number of attributed members eligible for inclusion in the measure population), and rate (a percentage derived from dividing the numerator by the denominator); National benchmarks (where available); and The number of points the ACO earned based on their 2017 performance. 6 OneCare Vermont earned 17 of 20 total possible points. Therefore, the ACO s overall quality score was 85%, combining performance on all 10 payment measures. To the extent possible, quality measures included in the VMNG contract were selected to align with measures included in the Vermont All-Payer ACO Model agreement. Many of these measures were identified because they represented an opportunity for improvement statewide. ACO performance exceeded the national 75 th percentile on three measures. ACO performance exceeded the national 50 th percentile on two measures. ACO performance was below the national 25 th percentile on one measure. National benchmarks were unavailable for four measures. OneCare Vermont was required to withhold some of the prospective payment to providers up-front 0.5% in 2017 to support a quality incentive program. The providers in the ACO are able to earn this money back through high quality performance on targeted quality measures. This type of payment incentive is provided to encourage high quality care. Because of the overall quality score, the ACO will distribute 85% of withheld payments to participating ACO providers. The ACO will reinvest the remaining 15% of withheld payments in quality improvement initiatives to support participating communities. 6 ACO-level performance was compared to national benchmarks when available. If national benchmarks were not available for the 2017 performance year, the ACO was awarded two points. In future years, ACO performance will be compared to prior year performance when national benchmarks are unavailable. 10

Table 2. Overview of VMNG Quality Performance, 2017 Measure Description NQF # Numerator Denominator Rate Quality Compass 2017 Benchmarks (CY 2016) National Medicaid Percentiles 25th 50th 75th 90th Points awarded Payment Measures 30 Day Follow-Up after Discharge from the ED for Alcohol and Other Drug 2605 49 162 30.25% N/A N/A N/A N/A 2 Dependence^ 30 Day Follow-Up after Discharge from the ED for Mental Health^ 2605 157 194 80.93% N/A N/A N/A N/A 2 Adolescent Well Care Visits N/A 3335 5800 57.50% 43.06 50.12 59.72 68.06 1.5 All Cause Unplanned Admissions for Patients with Multiple Chronic Conditions* CMS ACO #38 (under NQF review) 13 880 1.48% N/A N/A N/A N/A 2 Developmental Screening in the First 3 Years of Life 1448 1205 2017 59.74% 15.70 36.00 50.50 N/A 2 Diabetes Mellitus: Hemoglobin A1c Poor Control (>9%)* 0059 116 368 31.52% 48.57 41.12 35.52 29.07 2 Hypertension: Controlling High Blood Pressure 0018 230 356 64.61% 47.69 56.93 64.79 71.69 1.5 Initiation of Alcohol and Other Drug Dependence Treatment 0004 287 811 35.39% 35.79 40.72 45.13 50.00 0 Engagement of Alcohol and Other Drug Dependence Treatment 0004 143 811 17.63% 7.98 12.36 16.25 21.31 2 Screening for Clinical Depression and Follow-Up Plan 418 117 247 47.37% N/A N/A N/A N/A 2 Total Points Earned 17 Reporting Measures Follow-Up after Hospitalization for Mental Illness (7 Day Rate) 0576 67 181 37.02% 34.00 46.36 56.22 65.01 N/A Timeliness of Prenatal Care 1517 (No Longer Endorsed) 221 315 70.16% 77.66 83.56 88.59 91.67 N/A ^ denotes first-year HEDIS measures for which benchmarks are not yet available * denotes measures for which a lower rate indicates higher performance denotes measure with multi-state benchmarks: 26 states reporting (FFY 2016) Key: Performance Compared to National Benchmarks Equal to and below 25th percentile (0 points) Above 25th percentile (1 point) Above 50th percentile (1.5 points) Above 75th percentile (2 points) Above 90th percentile (2 points) 11