RAND Technical Expert Panel Explores Measure Concepts for Medicare Advantage and Part D VBAs 

RAND convened a technical expert panel (TEP) in February 2022 to gather input about potentially developing a measure to capture value-based care arrangements (VBAs) that Medicare Advantage (MA) organizations have with contracted providers. The Centers for Medicare and Medicaid (CMS) could consider including such a measure in future MA and Part D Star Ratings.  

This blog summarizes the RAND TEP conference proceedings, which were published June 17. As a developer and steward of many measures used in VBAs, PQA is sharing information about the TEP as a resource for its members and all stakeholders involved in VBAs, especially those involving medication use.  

The 2022 PQA Leadership Summit is focused on value-based care and contracting – and opportunities and challenges related to measuring value in medication use. An invitation-only event for PQA members, the summit annually convenes thought leaders and decision makers to discuss strategies and opportunities to address national priorities in medication use quality. 

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The first item the TEP considered was how to classify VBAs. One recommendation is to use the Health Care Payment Learning and Action Network Alternative Payment Model (APM) or a similar framework. The APM Framework categorizes VBAs into four arrangements:  

  • Fee-for-service with no link to quality and value;  
  • Fee-for-service with a link to quality and value;  
  • APMs built on fee-for-service architecture; and  
  • Population-based payments.  

The TEP expressed concern about categorizing VBAs due to many nuances.  

The TEP discussed this measure’s potential impacts and unintended and expressed great interest in any evidence surrounding measuring VBAs between plans and providers impacting quality of care for MA patients.  

Additionally, the TEP seeks evidence that shows improvement or decline in quality based on measuring VBAs and identifying patient or provider populations where exceptions might exist. Some mentioned provider exceptions include rural providers, special need plans, specialized providers and safety net hospitals.  

Documented evidence shows an increase in performance correlated with the number of enrollees a provider cares for. Furthermore, the group sought to define providers, highlighting that pharmacies currently contract with plans to address gaps in care, but typically those VBAs exist in the commercial sector, not MA plans. The TEP noted regional variety in provider acceptance to take on financial risk and that this measure may place a greater focus on financial risk than quality.   

Additional considerations focused on:  

  • How to quantify VBA participation, such as providers participating in a VBA, total reimbursements or MA-covered lives; 
  • How to capture physician organizations who subcontract care;   
  • How to reimburse care provided in multiple settings or multiple providers; and  
  • How to not penalize providers who cannot care for more enrollees.  

The TEP considered data collection challenges, including feasibility, lack of resources and lack of clarity on how to streamline data collection and reporting. Currently, each state has its own VBA reporting requirements that plans must meet which places additional burden on health plans servicing multiple states.  

The TEP recommended discussing an auditing or validation process until there is more clarity around data collection and reporting requirements for this measure. The TEP also questioned if quality measures in VBAs will have to align, and if so, how much, to the measures CMS uses to assess quality in MA plans. They noted that lack of alignment might cause a burden on providers and contribute to uncertainty about which measures to focus limited resources on.   

Overall, the TEP believes there is validity in building a measure to track VBAs but highlight those results should be shared with beneficiaries and standardizing data collection and reporting will be the key to successful implementation. 

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