September 2022

Enhancing your D-SNP and Medicare performance through ACO REACH

By Gen Gillespie

The Center for Medicare and Medicaid Innovation (CMMI) recently announced its list of participants in the redesigned version of the Global and Professional Direct Contracting program, now known as ACO REACH. 

The functions of this dynamic program are two-fold. For providers, ACO REACH is designed to encourage and accelerate the adoption of value-based care metrics and performance levers in service of Medicare Fee-for-Service beneficiaries. For Medicare beneficiaries, ACO REACH offers access-enhanced supplemental benefits beyond the standard Medicare Part A and B benefits that cover professional, outpatient, and hospital services.

Across all of these efforts, ACO REACH maintains a sharp focus on health equity that differentiates it from value-based payment models of the past. Whereas providers who care for underserved communities have often been penalized in those “one-size-fits-all” payment programs, providers recognized by ACO REACH work to heal, rather than widen, health disparities across communities.

Such novel and humanistic principles aren’t just at the heart of ACO REACH — they’re fully aligned with Belong Health’s mission to create local and community-oriented healthcare systems. Our shared sense of purpose is just one of many reasons why Belong Health is proud to have been chosen for participation in ACO REACH. 

Over the months and years to come, we look forward to partnering with payers (in this case, CMS) and providers in delivering compassionate and patient-focused care to those most in need.

Now, let’s explore how to leverage ACO REACH to complement an overarching strategy for Medicare and government programs — and to execute effective health equity plans. 

First and foremost, what are the requirements of ACO REACH participants, where health equity is concerned?  

According to CMMI, all ACO REACH entities must submit an official Health Equity Plan (HEP) by March 31, 2023. This deadline gives an ACO REACH entity 90 days in which to identify community disparities and health equity drivers among its aligned Medicare beneficiaries.  

With your March deadline in mind, we recommend following Belong Health’s three-step planning process towards the development of a robust health equity plan.

Dictionary of health equity

1.  Define ‘Health Equity’

Every community has different needs, dynamics, and demographics. As such, CMMI allows Accountable Care Organizations to identify and address key health equity priorities in their respective communities and, in turn, to define what health equity means for their respective populations. To help arrive at those definitions, here are a few questions you might consider:

  • Are you seeing inequitable access to care?  
  • Is there a high variation in quality performance within your population? 
  • Are those disparities defined by race, gender, age, or disability status? 

As an ACO REACH participant, awareness of community needs and equity gaps is paramount, and answering these three questions will prove key to the development of your unique health equity plan. By the end of this quick process, a fuller understanding of your own community will have naturally revealed itself to you.

Medical group of stakeholders

2. Plan with a multi-stakeholder governance model 

A multidisciplinary task force being critical to the planning of health equity intervention, it’s fortunate CMMI has already created a framework through which such a task force can be launched.

CMMI requires the Board of Directors of an ACO REACH entity to seat 75% provider participation with at least one consumer advocate and one Medicare beneficiary. Such a framework offers tremendous opportunity for built-in engagement between the provider and beneficiary communities — and aims to empower each Board to better understand inequities in care, prioritize key issues to address those inequities, and develop interventions that will meet the needs of beneficiaries.  
At Belong Health, we enthusiastically recommend the formation of a health equity subcommittee to:

  • Provide input on key inequities in the community 
  • Assist with gaining buy-in on interventions from participating ACO providers
  • Evaluate outcomes to ensure interventions meet the aims of the ACO REACH entity

With this model, ACO REACH participants benefit from an up-close look at the healthcare challenges faced in each community. Additionally, board members are empowered to address those challenges and to hold leadership accountable in planning and executing on a health equity plan.

Data center

3. Lead With Data

No one-size fits all plan can address the unique needs of your community. Although many health equity plans may look similar, each ACO must ensure its strategies are localized and specific to the population and community it serves.  

By definition, health equity for a High Needs ACO (made up of predominantly dual-eligible, under-65 disabled, and or chronically ill Medicare beneficiaries) will have different requirements than will a Standard/New Entrant ACO (made up of Medicare over-65 beneficiaries). Analysis of clinical and demographic data is a critical step in the planning and execution process, as it allows you to monitor progress against the plan.  
Without transparent, timely, and measurable metrics, the ACO will not be able to demonstrate improvements. As such, the first data-driven question in setting your plan should define, with specificity, what you want to measure.

For example, if you want to improve the rate or timeliness of preventative healthcare screenings categorized by race, gender, or age, it’s worthwhile to note this data is typically available and collected via CMS claims and clinical records. However, if you want to measure and improve metrics related to food insecurity, housing insecurity, or lack of transportation within your population, those data elements will need to be defined and sourced elsewhere.

Whatever your interests, in setting your plan, begin with data that is available to you as part of your standard processes, and then work with partners and your technology, analytics, and clinical teams to fill any gaps. 

“Ideas are Easy, Execution is Hard”

Once your health equity plan is set, it must be documented by the health equity subcommittee. That documentation can then be shared with ACO staff, with participating providers, and, ideally, with beneficiaries who share responsibility for implementing the plan. Obtaining buy-in, helping stakeholders understand the performance measures in the plan and how frequently they will be measured, and, most importantly, iterating and optimizing as you begin to monitor the effectiveness of the interventions, are all critical steps on the pathway to success. 

Examples of Health Equity in practice

As your ACO REACH population grows and changes in composition, you may need to modify your health equity plan internally and with CMMI. Insights gleaned from transparent measurement of health equity interventions will allow you to develop more effective interventions. For best results, integrated feedback from staff, providers, and beneficiaries should also be heavily weighted in process and performance improvement.  

At every point in this process, it is valuable to know when to ‘cut bait.’  Embrace the reality that implementation of your plan will be difficult. You must be able to measure when your interventions are not having the intended effect, and you must be able to create a feedback loop to your health equity governance committee that will aid in refining your interventions. 

At Belong Health, such self-awareness is in keeping with our core company values of “staying curious” and “doing the right thing, even when it’s the hard(er) thing.”

The Belong Health team is excited to live out these and all of our values as we tackle the new challenges presented by ACO REACH. Health equity is a core tenet of standing up and operating high-performing D-SNP and Medicare products, and ACO REACH dramatically furthers our efforts to address disparities in cultural, demographic, and health-oriented outcomes by measuring and monitoring the data needs for each of the communities we are honored to serve.