PSH Advocacy

ASA and the PSH Learning Collaborative leadership are actively engaging key stakeholders, including CMS and private payers to advance the PSH model. As heath care reform and other innovative payment and delivery models begin to diffuse into the environment, the PSH model is well positioned to help health care providers succeed. ASA is engaged in the following activities:

CMS Communications

ASA is in continuous communication with the Centers for Medicare and Medicaid Services (CMS) officials to advance the PSH model. Based off these discussions and understanding of regulatory ASA leaders have determined that there are three pathways for the PSH to become involved within MACRA’s Quality Payment Program (QPP). (Noted that none of these options are mutually exclusive.)

  1. PSH Integrated into MIPS reporting –
    The PSH is a proven delivery model that can help improve patient care and therefore improve clinicians’’ MIPS scoring potential.
  2. PSH Integrated into Existing model – 
    The PSH is a flexible delivery model that can integrate into existing MIPS APMs and Advanced APMs to achieve improved clinical outcomes and cost reduction.
  3. PSH Integrated into new Advanced APM –
    This PSH integrated APM model could be designed to meet all three of the criteria for an AAPM (financial risk, quality and HIT) and to expand Advanced APM opportunities to a broader base of specialties.

Regulatory (e.g. MIPS) Integration

For CY 2018 MIPs reporting, CMS has recognized two sets of PSH activities as an Improvement Activities (IA).

  1. PSH Care Coordination:
    Allows for reporting of strategies and processes related to care coordination of patients receiving surgical or procedural care within a PSH.
    • Coordinate with care managers/navigators in preoperative clinic to plan and implementation comprehensive post discharge plan of care;
    • Deploy perioperative clinic and care processes to reduce post-operative visits to emergency rooms:
    • Implement evidence-informed practices and standardize care across the entire spectrum of surgical patients; or
    • Implement processes to ensure effective communications and education of patients' post-discharge instructions.
  2. Use of Patient Safety Tools:
    Use of tools that assist specialty practices in tracking specific measures that are meaningful to their practice, such as use of a surgical risk calculator, evidence based protocols such as Enhanced Recovery After Surgery (ERAS) protocols, the CDC Guide for Infection Prevention for Outpatient Settings, predictive algorithms, or other such tools.

    3. Note: CMS has clarified that ASA’s submission PSH Population Management strategies (pdf)  is encompassed in the existing Use of Patient Safety Tools activity.

Both activities have been assigned a weight of Medium, which means that reporting of these PSH activities will constitute 50% of all the reporting requirements for the Improvement Activities category under MIPS. Additionally, for clinicians designed as non-patient facing (of which most anesthesiologists will be designated) can receive 100% of their requirements through these two activities.

The PSH Care Coordination activity has received the rare distinction of being eligible for the Advancing Care Information (ACI) bonus. Typically, participants would have to report wholly separate measures for both the IA and the ACI measures, however, CMS has recognized the PSH care coordination activity as also counting towards 10% of their ACI score. Only one in four activities has been recognized for this bonus and it represents a huge step forward for providers who spend significant time and resources in providing care coordination in a PSH pilot.

Monitoring PTAC & Multi-specialty APM Collaboration

The Physician-Focused Payment Model Technical Advisory Committee (PTAC) is a panel of 11 members created by the MACRA legislation. The purpose of the committee is to evaluate stakeholder-submitted physician-focused payment models (PFPMs) against a list of criteria defined in statue by the Health and Human Services (HHS) secretary.

Since the PTAC process is open to the public, in which stakeholders from all areas of healthcare can participate, the ASA closely monitors the submissions to the Committee and is currently participating in the process by submitting comment letters and working with outside submitters as appropriate.