Perspective

Jenkins: Education and Data the Keys to Healthcare Compliance

August 2, 2020

LMI Staff

Stephen Jenkins joined LMI in 2018 after four years with the Center for Medicare & Medicaid Innovation (CMMI), where he led the Accountable Care Organization (ACO) Investment Model and the Medicare Advantage Value-Based Insurance Design (VBID) Model. In this role, he managed the model operations, including policy development, IT requirements, contractor work plans, communications materials, and operational timelines. Before CMMI, he served as a health policy associate for the U.S. Senate Committee on Finance, focused on reforming the Medicare physician payment system.

You’ve said the ACO Investment Model was a point of pride from your time at CMMI. Explain the significance.

CMMI tests models of care that seek to improve the quality of care, reduce costs, and foster a more efficient healthcare system. It was a tremendous opportunity to shape and build a model from the ground up that was ultimately successful at expanding value-based care to rural areas and lowering the cost of care to the Medicare system. The work my team did to draft the policy and move through the model lifecycle to operationalize, iterate, and deliver an efficient model was an incredible experience.

How does the ACO Investment Model work?

The model was designed to promote access to coordinated care in rural and underserved areas and to provide an opportunity for healthcare providers to participate as ACOs in the Medicare Shared Savings Program. The conventional risk of ACOs comes from the need to invest upfront in care management activities, with the prospect of savings realized over the long term. Rural and smaller providers have a higher sensitivity to that risk, because they don’t have the cash reserves to make large investments.

The model allowed providers to receive upfront and ongoing funding from CMS to invest in infrastructure to better manage the care of their beneficiaries. This improvement in care coordination helped reduce readmissions, maintain drug adherence, and reduce unnecessary care, which led to a reduction in health expenditures and to shared savings that could be recouped by CMS.

— Stephen Jenkins

What brought you to LMI?

When I worked with LMI, their commitment to the success of the model impressed me. As a government employee, it is incredibly valuable to have a contractor that is committed to going the extra mile with you. LMI felt like a true partner throughout the process, very hands-on and supportive of not just CMMI and my team but also the model participants. LMI leveraged data to identify model risks and educated participants, focusing the resources available in the model on the participants that needed the most support, giving them the knowledge and resources to be successful.

You mentioned LMI’s hands-on approach to supporting providers who participate in CMMI models. Why is participant education so important to model compliance?

The objective of CMMI models is to give participating providers flexibility to try things differently, so the “rules of the road” can sometimes be vague in terms of what methods are acceptable as we try to right-size the level of care to meet the individual’s needs while controlling costs. Educating participants about how the model works is key. We don’t want participants constantly looking over their shoulder; we want to lessen their compliance burden so they can focus on providing care.

LMI has worked to create a compliance approach for several CMS programs and CMMI models that utilizes education to improve participant understanding of the model requirements. This will help them remediate any compliance issues quickly and decrease the number of compliance issues in the model over time.

COVID-19 has put unprecedented strain on healthcare providers. How do you ensure compliance activities do not compound it?

Helping providers participate in CMMI models appropriately with minimal burden is always a priority. If compliance becomes a distraction from the core mission of providing patient care, that’s counterproductive to the model—even more so during a public health crisis.

At LMI, we increasingly rely on data-driven oversight to reduce the burden shared by model participants. By restructuring our compliance processes to leverage data more effectively, we are monitoring model health and identifying risks for mitigation, leading to targeted remediation. So long as providers are acting in good faith, compliance actions should be supportive, cooperative, and educational rather than punitive, especially in this environment. We want all parties to have the best opportunity for success and to deliver the high-quality healthcare our citizens need.

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