CHART NOFO_Final_508v_Final.pdf
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U.S. Department of Health and Human Services
Centers for Medicare & Medicaid Services
Community Health Access and Rural Transformation Model
Community Transformation Track
Notice of Funding Opportunity Type: New
Funding Opportunity Award Type: Cooperative Agreement
Notice of Funding Opportunity Number: CMS-2G2-21-001
CFDA: 93.624
Notice of Funding Opportunity Posting Date: September 15, 2020
Applicable Dates:
Letter of Intent to Apply Due Date: January 18, 2021
Electronic Application Due Date: February 16, 2021 3:00 PM Eastern U.S. Time
Anticipated Issuance Notice(s) of Award: June 16, 2021
Anticipated Period of Performance: 7 years (1 Pre-Implementation Period and 6 Performance
Periods)
Table of Contents Executive Summary
A. Program Description
A.1. Purpose
A.2. Authority to Test the Model
A.3. Background
A.4. Program Requirements
A.4.1. Key Terms
A.4.2. Model Design and Funding Structure
A.4.3 Lead Organization and the Community
A.4.4. Community Partners
A.4.5. Value-Based Payment
A.4.6. Operational Flexibilities under the Model
A.4.7. Quality Strategy
A.4.8. Implementation and Learning Support
A.4.9. Model Timeline
B. Federal Award Information
B.1. Total Funding
B.2. Award Amount
B.3. Anticipated Award Dates
B.4. Period of Performance
B.5. Number of Awards
B.6. Type of Competition
B.7. Type of Competition
C. Eligibility Information
C.1. Eligible Applicants
C.2. Cost Sharing or Matching
C.3. Letter of Intent
C.4. Ineligibility Criteria
C.5. Single Application Requirement
C.6. Continued Eligibility
C.7. EIN, DUNS, and SAM Regulations
C.8. Faith-Based Organizations
C.9. Other Eligibility Requirements
D. Application and Submission Information
D.1. Address to Request Application Package
D.2. Content and Form of Application Submission
D.3. Unique Entity Identifier and System for Award Management (SAM)
D.4. Submission Dates and Times
D.5. Intergovernmental Review
D.6. Cost Restrictions
D.7. Mandatory Disclosure
D.8. Other Submission Requirements (if applicable)
E. Application Review Information
E.1. Criteria
E.1.1. Project Abstract
E.1.2. Project Narrative
E.1.3. Additional Required Documentation
E.2. Review and Selection Process
E.3. Federal Awardee Performance Integrity Information System (FAPIIS)
F. Federal Award Administration Information
F.1. Federal Award Administration Information
F.2. Administrative and National Policy Requirements
F.3. Terms and Conditions
F.4. Cooperative Agreement Terms and Conditions of Award
F.5. Reporting
F.5.1. Financial Reports
F.5.2. Monitoring
F.5.3. Evaluation
G. CMS Contacts
G.1. Programmatic Questions
G.2. Administrative/Budget Questions
Appendix I. Guidance for Preparing a Budget Request and Narrative:
Appendix II. Application and Submission Information
Appendix III. Business Assessment of Applicant Organization
Appendix IV: Accessibility Requirements
Appendix V. Review and Selection Process
Appendix VI. Application Check-Off List Required Contents
Appendix VII. Examples of Health Care Delivery System Redesign
Appendix VIII. Additional Resources for Applicants: Literature and Funding Opportunities
Appendix IX. Medicaid Needs Assessment
Appendix X. Transformation Plan Requirements
Appendix XI. CPA Financial Methodology
Executive Summary
The Community Health Access and Rural Transformation (CHART) Model is a voluntary payment model designed to meet the unique needs of rural communities. The CHART Model will test whether aligned financial incentives, increased operational flexibility, and robust technical support promote rural health care providers’ capacity to implement effective health care delivery system redesign on a broad scale. The Center for Medicare & Medicaid Innovation
(CMMI) will evaluate the impact of the CHART Model on Medicare and Medicaid expenditures, access to care, quality of care, and health outcomes for rural residents.
CHART aligns with CMS’s Rethinking Rural Health initiative, which aims to ensure individuals in rural America have access to high quality, affordable health care by offering new and creative payment models.1 The CHART Model will include two tracks: 1) the Community Transformation
Track and 2) the Accountable Care Organization (ACO) Transformation Track. This Notice of
Funding Opportunity (NOFO) is for the Community Transformation Track only. Under the
Community Transformation Track, award recipients will receive cooperative agreement funding and a programmatic framework to assess the needs of their Community (as defined in section
A.4.3.1. Community Definition below) and implement health care delivery system redesign.
Hospitals participating in the Community Transformation Track Alternative Payment Model
(APM) will receive capitated payments. Capitated payments provide hospitals with a stable revenue stream and incentivize reductions in fixed costs and avoidable utilization.2 Operational flexibilities will be available for participating hospitals to relieve regulatory burden, emphasize high-value services, and support providers in care management for their beneficiaries.
Under the ACO Transformation Track, entities will receive upfront payments to establish or expand rural ACOs that participate in two-sided risk arrangements through the Medicare
Shared Savings Program. Building on the success of the ACO Investment Model (AIM), these upfront payments will help rural entities engage in value-based payment reform and support the participation of such rural ACOs in the Medicare Shared Savings Program, several tracks of which are Advanced Alternative Payment Models (Advanced APMs) for 2020.
Information for the ACO Transformation Track will be released at a later date to be specified by CMMI. The ACO Transformation Track is separate from the Community Transformation
Track and is not addressed in this NOFO.
Award recipients’ (herein referred to as "Lead Organizations”) participation in the Community
Transformation Track of the CHART Model will begin with a Pre-Implementation Period (1 year), during which they will recruit participating hospitals (herein referred to as "Participant
Hospitals” in accordance with section A.4.4.2. Participant Hospitals) and partner with them and other community stakeholders to develop a health care delivery system redesign strategy.
Following the Pre-Implementation Period, Lead Organizations, community stakeholders, and
Participant Hospitals will have 6 Performance Periods (6 years) to implement their health care delivery system redesign strategy and participate in the APM.
Item Description
HHS Awarding Agency
Centers for Medicare & Medicaid Services (CMS)
CMS Awarding Center
Center for Medicare & Medicaid Innovation (CMMI)
Notice of Funding Opportunity Title
Community Health Access and Rural Transformation (CHART)
Model: Community Transformation Track
Authorization
Section 1115A of the Social Security Act (the Act) as added by
Section 3021 of the Patient Protection and Affordable Care Act
(Pub. L. 111-148), as amended by the Health Care and Education
Reconciliation Act (Pub. L. 111-152), referred to collectively as the Patient Protection and Affordable Care Act
Federal Assistance Listing Number
93.624
Funding Opportunity Type
New
Funding Opportunity Number
CMS-2G2-21-001
Type of Award Cooperative Agreement
Type of Competition Open to all eligible applicants
Letter of Intent CMMI highly recommends that interested applicants submit a Letter of Intent; however, a Letter of Intent is not required.
Due Date for Letter of Intent (e.g., MM/DD/YYYY)
1/18/2021
Application Due Date & Time
2/16/2021 3:00 PM Eastern U.S. Time
Anticipated Issuance Notice(s) of Award
06/16/2021
Period of Performance Start Date
07/01/2021
Period of Performance End Date
06/30/2028
Anticipated Total Available Funding
$75,000,000
Estimated Maximum Award Amount
$5,000,000
Estimated Maximum Awards
A. Program Description
A.1. Purpose
The Centers for Medicare & Medicaid Services (CMS), through its Center for Medicare &
Medicaid Innovation (CMMI), will implement a new Model, the Community Health Access and
Rural Transformation (CHART) Model. The CHART Model aims to improve health care quality and reduce Medicare and Medicaid expenditures within rural communities. The CHART Model will harness the drive, creativity, and local expertise of rural communities and leverage national resources to improve access to care, quality of care, and health outcomes for rural residents.
CHART’s Community Transformation Track aims to catalyze modernization of rural health delivery systems by offering technical support, operational flexibilities, and an APM specifically designed for rural communities.
A.2. Authority to Test the Model
The authority for the CHART Model is section 1115A of the Social Security Act (the Act). Section
1115A of the Act authorizes the Secretary of the Department of Health and Human Services
(HHS) to test innovative payment and service delivery models to reduce Medicare, Medicaid, or
CHIP expenditures while preserving or enhancing the quality of beneficiaries’ care.
A.3. Background
Rural hospitals face significant barriers to maintaining financial stability, including low patient volumes and high average fixed costs, that undermine viability under traditional health care reimbursement mechanisms such as volume-based Fee for Service (FFS). Additionally, rural hospitals have more difficulty attracting and retaining a health care workforce.3 4
A volume-based Fee for Service (FFS) payment structure can exacerbate the adverse conditions experienced by rural health care systems. Under FFS, if volumes decline, the continuation of high-cost but essential service lines, such as obstetrics, gynecology, and cancer care, can become financially unviable. Stakeholders have shared that existing regulatory constraints can drive rural hospitals’ to maintain inefficient facility footprints. 5 In Medicare, APMs and
Advanced APMs have accelerated the reduction of health care costs and improved quality of care.6 However, rural health care providers have adopted Advanced APMs at lower rates compared to urban health care providers due to perceived issues in capacity for implementation and lack of flexibility for rural practices.7
To mitigate the barriers rural hospitals face when implementing health care transformation, the
Community Transformation Track of the CHART Model offers (1) funding to establish partnerships and technical support, (2) an APM specifically designed for the rural context, and
(3) operational flexibilities. Through the CHART Model, health care providers, as well as public and private payers, can collectively invest in increasing access to care, promoting quality, and improving the health outcomes of residents within their Community.
A.4. Program Requirements
A.4.1. Key Terms
TERM DEFINITION
Acute Care Hospital A hospital that provides inpatient medical care and other related services for surgery, acute medical conditions, or injuries (usually for a short-term illness or condition).
Advanced Alternative Payment Model (Advanced APM)
As set forth in 42 CFR 414.1305, Advanced APMs are APMs that meet the following three criteria (which are specified in 42 CFR 414.1415):
1. Require participants to use certified EHR technology
2. Provide payment for covered professional services based on quality measures comparable to those used in the MIPS quality performance category; and
3. Either: (1) is a Medical Home Model expanded under CMMI authority or (2) requires a participant to bear more than a nominal amount of financial risk
Advisory Council* The Advisory Council is a multi-stakeholder organization that will play an advisory role to the Lead Organization as they carry out their funded activities (Table 2. Funded Activities for Lead Organizations), such as providing critical feedback in the development and implementation of Transformation Plans and assistance with collaboration efforts with Participant Hospitals, the State Medicaid Agency (SMA), and other key Community stakeholders.
Aligned Payer* An Aligned Payer is an entity that makes payment for health care services and possesses the three
TERM DEFINITION
aligning characteristics outlined in Table 5. Payer Alignment Characteristics.
Alternative Payment Model (APM) For purposes of this NOFO, an Alternative Payment Model (APM) is a payment approach that gives added incentive payments to provide high quality and cost-efficient care. APMs can apply to a specific clinical condition, a care episode, or a population. For purposes of the Quality Payment Program, APM is codified in 42 C.F.R. 414.1305.
Capitated Payment Amount (CPA) Capitated payment amount is the prospectively set annual payment amount for a Participant Hospital for Eligible Hospital Services that the Participant Hospital furnishes. The CPA will be calculated by
CMMI.
Collaborative Governance Collaborative governance refers to the approach of collaboration at the community level that involves shared leadership of rural hospitals and other health care providers (e.g., FQHCs) via governance arrangements (e.g., overlapping council constituents) and possibly shared management, to support cooperation in sharing and/or coordinating resources within a geographic region.
Community* Community is a geographic area that meets the requirements in section A.4.3.1. Community Definition.
Community Transformation Track* The Community Transformation Track includes the following: cooperative agreement funding, operational flexibilities, and the Community Transformation Track APM, which prospectively sets an annual payment amount for a defined set of Eligible Hospital Services for Participant Hospitals.8
Critical Access Hospital (CAH) A state that has established a Medicare Rural Hospital Flexibility Program may designate certain facilities as Critical Access Hospitals (CAH). CMS will then certify a state-designated facility as a CAH if the facility meets certain requirements. CAHs receive cost-based reimbursement for most Medicare Part A and Part B services. Eligible hospitals must, among other requirements, meet the following conditions to obtain CAH designation:
1. Have 25 or fewer acute care inpatient beds
2. Be located more than 35 miles from another hospital or CAH or 15 miles if mountainous terrain with only secondary roads (some exceptions apply)
3. Maintain an annual average length of stay of 96 hours or less for acute care patients
4. Provide 24/7 emergency care services
CAHs are defined in section 1861(mm)(1) of the Social Security Act.
Discount Factor* Discount factor refers to the small percentage discount applied to the capitated payment amount (CPA). The specific discount factor for a Community is determined by its total Medicare FFS revenue under the capitated payment arrangement at the Community-level, as specified in Appendix XI. CPA Financial Methodology.
Eligible Hospital Service An Eligible Hospital Service is any health care service that meets the following criteria:
1. Is covered under Part A or Part B of Title XVIII of the Act;
2. Meets the Service Inclusion Criteria discussed in section A.4.5.1. Capitated Payment; and
3. Does not meet the Service Exclusion Criteria discussed in section A.4.5.1. Capitated Payment.
Federally Qualified Health Center
(FQHC)
Federally Qualified Health Center (FQHC) status is a Centers for Medicare and Medicaid Services (CMS) designation indicating eligibility for reimbursement using specific payment methodologies. Federally Qualified Health Center is defined in sections 1861(aa)(4) and 1905(l)(2)(B) of the Act. The types of FQHCs include:
1. Health Center Program award recipients that receive federal funding under section 330 of the Public Health Service (PHS) Act and entities receiving funding from such a grant as a subrecipicent of the Health Center Program award recipient.
2. Health Center Program look-alikes. Look-alikes do not receive federal funding under section 330 of the PHS Act; however, to receive look-alike designation and associated Federal benefits, look-alikes must meet the Health Center Program requirements.
3. Outpatient health programs or facilities operated by a Tribe or Tribal/Indian organization under the Indian Self Determination and Education Assistance Act (Public Law 93-638) or by an urban Indian organization receiving funds under title V of the Indian Health Care Improvement Act for the provision of primary health services.
The Health Resources and Services Administration (HRSA) administers grant funding (as applicable) and oversight of the first two types of FQHCs (Health Center Program award recipients and look-alikes), both of which must meet a stringent set of requirements. These requirements are detailed in the Health Center Program Compliance Manual available.9
Hub-and-Spoke Model Hub-and-Spoke is a model of care that arranges service delivery assets into a network consisting of an anchor establishment (hub) that offers a full array of services, which is complemented by secondary establishments (spokes) which offer more limited service arrays. Patients who need more intensive services are routed from a spoke to a hub.10
Lead Organization* A Lead Organization is a CHART Model award recipient under the Community Transformation Track. It is responsible for forming the Advisory Council, recruiting Participant Hospitals, engaging the SMA, developing and implementing the Transformation Plan, and overseeing the implementation of the Community Transformation Track APM. There can only be one Lead Organization per Community. See section A.4.3 Lead Organization and the Community.
Participant Hospital* A Participant Hospital is an acute care hospital (defined as a “subsection (d) hospital” in section 1886(d)(1)(B) of the Act) or CAH that meets the requirements in section A.4.4.2. Participant Hospitals.
Payer A Payer is an entity furnishing payments for health care services.
Rural Health Clinic (RHC) A Rural Health Clinic (RHC) is a clinic located in a rural, medically under-served area in the United States that has a separate reimbursement structure from the standard medical office under the Medicare and Medicaid programs. The RHC program is intended to increase access to primary care services for patients in rural communities.
RHCs can be public, nonprofit, or for-profit health care facilities. To receive certification, they must be located in rural, underserved areas. They are required to use a team approach of physicians working with non-physician health care providers such as nurse practitioners (NP), physician assistants (PA), and certified nurse midwives (CNM) to provide services. The clinic must be staffed at least 50% of the time with a NP, PA, or CNM. RHCs are required to provide outpatient primary care services and basic laboratory services. Definitions are set out at sections 1861(aa)(2) and 1905(L)(1) of the Act.
Subrecipient According to 2 CFR § 200.93, subrecipient means a non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program; but does not include an individual that is a beneficiary of such program. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency.
Transformation Plan* A Transformation Plan is a detailed description of the health care delivery system redesign strategy that will be carried out under the Community Transformation Track of the CHART Model.
Transformation Plan requirements are outlined in section A.4.3.2. Transformation Plan.
*Key terms marked with an asterisk are specific to the CHART Model
A.4.2. Model Design and Funding Structure
Understanding that rural communities face unique challenges to implementing health care delivery system redesign, the Community Transformation Track of the CHART Model consists of three core program elements designed to set up rural communities for success.
1. Funding to establish partnerships and technical support. The Community
Transformation Track of the CHART Model will provide Lead Organizations with cooperative agreement funding to implement health care delivery system redesign that is both evidence informed and tailored to the Community’s needs. Lead Organizations will be able to use cooperative agreement funding to establish partnerships with community stakeholders to develop a health care delivery system redesign strategy, recruit Participant Hospitals, and procure technical support.
2. Operational flexibilities. The CHART Model makes operational flexibilities available to support Communities in implementing health care delivery system redesign. Participant
Hospitals may leverage operational flexibilities in their Community to relieve regulatory burden, emphasize high-value services, and support providers in care management for their beneficiaries. Operational flexibilities will be made available through a combination of model design elements and waivers under section 1115A authority as necessary to test the Model.
3. Value-based payment. Participant Hospitals will receive capitated payments. This stable revenue stream will incentivize Participant Hospitals to lower fixed costs, reduce potentially avoidable utilization, and improve quality of care.
The Community Transformation Track of the CHART Model will begin with a Pre-
Implementation Period, during which a Lead Organization will collaborate with key participants and community stakeholders to develop a strategy to implement health care delivery system redesign (as described in section A.4.3.2. Transformation Plan). In total, Lead Organizations will have six Performance Periods to implement their Transformation Plan. The Lead Organization will receive up to $5M in cooperative agreement funding. All cooperative agreement funding will be tied to performance requirements. The funding amounts, prerequisites, Budget Periods, and Performance Periods are outlined in Table 1. Funding Timeline and Prerequisites below.
Table 2. Funded Activities for Lead Organizations in section A.4.3 Lead Organization and the
Community describes the activities for which Lead Organizations are expected to use Model funds. To receive funding for the Second Budget Period through the Seventh Budget Period, Lead Organizations must submit a non-competing continuation application. Additional instructions will be included in the terms and conditions of the cooperative agreement.
Table 1. Funding Timeline and Prerequisites
Cooperative
Agreement
Timing
Model Timing Funding
Available Funding Prerequisites
First Budget Period
Pre- Implementation Period
Up to $2,000,000
Notice of Award (NoA) issued to Lead Organization
Acceptance of cooperative agreement terms and conditions
Second Budget Period
Performance Period 1
Up to $500,000 Satisfactory participation in the Pre-Implementation Period as described in the cooperative agreement terms and conditions
Transformation Plans approved by CMMI prior to Performance Period 1
Participant Hospitals’ combined Medicare FFS Revenue projected to be under a capitated payment arrangement in Performance Period 1 is greater than or equal to the minimum amount in the CMMI-approved Transformation Plan
Award of non-competing continuation (NCC) for Performance Period 1
Third Budget Period
Performance Period 2
Up to $500,000 Satisfactory participation in Performance Period 1 as described in the cooperative agreement terms and conditions
Updated Transformation Plans approved by CMMI prior to Performance Period 2
Participant Hospitals’ combined Medicare FFS Revenue projected to be under a capitated payment arrangement in Performance
Agreement
Timing
Model Timing Funding
Available Funding Prerequisites
Period 2 is greater than or equal to such amount for Performance Period 1
Award of NCC for Performance Period 2
Fourth Budget Period
Performance Period 3
Up to $500,000 Satisfactory participation in Performance Period 2 as described in the cooperative agreement terms and conditions
Updated Transformation Plans approved by CMMI prior to Performance Period 3
Participant Hospitals’ combined Medicare FFS Revenue projected to be under a capitated payment arrangement in Performance Period 3 is greater than or equal to such amount for Performance Period 2
Award of NCC for Performance Period 3
Fifth Budget Period
Performance Period 4
Up to $500,000 Satisfactory participation in Performance Period 3 as described in the cooperative agreement terms and conditions
Updated Transformation Plans approved by CMMI prior to Performance Period 4
Participant Hospitals’ combined Medicare FFS Revenue projected to be under a capitated payment arrangement in Performance Period 4 is greater than or equal to such amount for Performance Period 3
Agreement
Timing
Model Timing Funding
Available Funding Prerequisites
Award of NCC for Performance Period 4
Sixth Budget Period
Performance Period 5
Up to $500,000 Satisfactory participation in Performance Period 4 as described in the cooperative agreement terms and conditions
Updated Transformation Plans approved by CMMI prior to Performance Period 5
Participant Hospitals’ combined Medicare FFS Revenue projected to be under a capitated payment arrangement in Performance Period 5 is greater than or equal to such amount for Performance Period 4
Award of NCC for Performance Period 5
Seventh Budget Period
Performance Period 6
Up to $500,000 Satisfactory participation in Performance Period 5 as described in the cooperative agreement terms and conditions
Updated Transformation Plans approved by CMMI prior to Performance Period 6
Participant Hospitals’ combined Medicare FFS Revenue projected to be under a capitated payment arrangement in Performance Period 6 is greater than or equal to such amount for Performance Period 5
Award of NCC for Performance Period 6
A.4.3 Lead Organization and the Community
CMMI will award cooperative agreement funding for the Community Transformation Track of the CHART Model to a single entity, referred to as a Lead Organization. The Lead Organization will be responsible for driving health care delivery system redesign by leading the development and implementation of Transformation Plans as well as convening and engaging the Advisory
Council. Lead Organizations will also be responsible for ensuring compliance with Model requirements and with any requests from CMMI for additional data or other supplemental information. A potential Lead Organization must submit, as part of its application, documentation that demonstrates it meets each of the following requirements for selection:
1. A presence in the Community one year prior to the publication date of this NOFO.
Examples of “presence” include advocating for (e.g. a representative organization), providing services to, or otherwise serving beneficiaries within the Community). While a physical presence in the Community is not required, a relationship with the Community is required.
2. Expertise in rural health issues, in particular specific diseases, health disparities, barriers to accessing care, policy, and other key factors that significantly influence health outcomes, particularly those prevalent in the Community.
3. Experience, either through direct management or through a partnership, in designing and implementing APMs.
4. Received and successfully managed one or several health-related grant(s) or cooperative agreement(s) totaling at least $500,000 over the last three years.
5. Experience in each of the following areas:
a. Engaging and maintaining provider participation in APMs or CMMI demonstration projects/models.
b. Establishing, modifying as needed, and maintaining agreements between health care providers.
c. Conducting outreach, developing, and managing relationships with diverse health care-related stakeholders.
Any organization that does not meet all of the criteria listed above is ineligible to serve as a
Lead Organization. Examples of entities eligible to serve as Lead Organizations include, but are not limited to, State Medicaid Agencies (SMAs), State Offices of Rural Health (SORHs), local public health departments, Independent Practice Associations (IPAs), and Academic Medical
Centers (AMCs).
A.4.3.1. Community Definition
Lead Organizations will be responsible for defining the parameters of their Community, for the purposes of the CHART Model. Each Community must meet the following criteria:
1. Encompass either (a) a single county or census tract or (b) a set of contiguous or non-contiguous counties or census tracts. Each county or census tract must be classified as rural, as defined by the Federal Office of Rural Health Policy’s list of eligible counties and census tracts used for its grant programs.11
2. At the time of application submission, include a minimum of 10,000 Medicare FFS beneficiaries whose primary residence is within the Community.
NOTE: Lead Organization’s definition of their Community is subject to CMMI review and approval. During application review, CMMI will ensure that there is not overlap between Lead
Organizations’ defined Communities.
A.4.3.2. Transformation Plan
Lead Organizations will leverage technical support and input from Community Partners, i.e. its
Advisory Council, Participant Hospitals, and the SMA as described in section A.4.4. Community
Partners, to design and implement Transformation Plans that are both tailored to the
Community’s needs and informed by best practices.
Transformation Plans are Lead Organizations’ descriptions of their health care delivery system redesign strategy. Each Lead Organization, in collaboration with its Advisory Council (including the SMA) and its Participant Hospitals, will develop and submit Transformation Plans. All
Transformation Plans must be reviewed and approved by CMMI. A Lead Organization will submit their first Transformation Plan during the Pre-Implementation Period, and subsequently submit updates on an annual basis. At a minimum, CMMI will review each Transformation Plan prior to the start of each Performance Period and provide feedback to the Lead Organization as necessary leading up to Transformation Plan approval. A Lead Organization may modify its
Transformation Plan more frequently than the schedule set by CMMI, for example if they want to implement a programmatic change on a more immediate basis. Upon CMMI approval, each
Lead Organization must begin implementing its Transformation Plan in Performance Period 1.
CMMI requires Transformation Plans to focus on population health disparities present in the
Community. Specifically, Transformation Plans must address at least one of the following:
behavioral health treatment, substance use disorder treatment, chronic disease management and prevention, or maternal and infant health. CMMI also requires Transformation Plans to include strategies to expand the use of telehealth and other technology to support care delivery improvement. Communities may leverage regulatory flexibilities under the Model to implement telehealth expansion in regards to Section 1834(m) of the Act. In addition, Communities are encouraged to address social determinants of health in their Transformation Plans. To address the social determinants of health, Lead Organizations may utilize cooperative agreement funding, leverage the transportation Medicare beneficiary engagement incentive (see section
A.4.6. Operational Flexibilities under the Model) or engage the SMA to implement a change in
Medicaid policy. More information on integrating social determinants within health care delivery system redesign will be made available to Communities that have been selected to participate.
At CMMI’s sole discretion and to the extent necessary to test the Model, certain waivers of
Medicare and Medicaid requirements will be available to facilitate implementation of
Transformation Plans (see section A.4.6. Operational Flexibilities under the Model and
Appendix IX. Medicaid Needs Assessment for more information). For example, some Lead
Organizations and/or Participant Hospitals may use such waivers to facilitate converting rural hospitals to rural emergency and outpatient-only facilities or establish hub-and-spoke arrangements that distribute and coordinate services by need throughout a Community.
CMMI will use the Transformation Plans to track, monitor, and evaluate Lead Organizations’ progress against the Model’s Community Transformation Track goals. Cooperative agreement funding for each Performance Period is contingent on CMMI approval of Transformation Plans in budget periods 2 through 7 (see Table 1 Funding Timeline and Prerequisites). Appendix X.
Transformation Plan Requirements outlines the basic components of Transformation Plans.
CMMI will provide additional guidance to Lead Organizations on Transformation Plan requirements upon award.
A.4.3.3. Lead Organization Funded Activities
Lead Organizations can use cooperative agreement funding for any of the purposes described in
Table 2. below. The Lead Organization will be responsible for determining the budget allocations for staff time and infrastructure costs consistent with the Model terms and conditions, as well as demonstrating how they and their subrecipients will use funds to accomplish their respective roles in Model implementation. The Lead Organization will be responsible for the receipt and management of this funding in accordance with the Model terms and conditions and applicable federal laws. Additionally, Lead Organizations must demonstrate in their Transformation Plans, that Aligned Payers meet the requirements of the
Model (for more information on Aligned Payers, see section A.4.5.3. Multi-payer Alignment).
Table 2. Funded Activities for Lead Organizations
Timing Lead Organization Activities
Pre-Implementation Period (1 year)
Constitute and convene the Advisory Council in accordance with the Model terms and conditions
Manage cooperative agreement funds
Partner with the SMA (if the SMA is not the Lead Organization), to ensure necessary Medicaid authorities are in place to align the state’s Medicaid program with the Model
Recruit Participant Hospitals to the Model
Timing Lead Organization Activities
Recruit commercial payers to participate as Aligned Payers in the Model and oversee their compliance with the requirements outlined in section A.4.5.3 Multi-payer Alignment
Provide or procure technical assistance to support development of the Transformation Plan and prepare Participant Hospitals to enter capitated payment arrangements with CMS
Create, submit for CMMI approval, revise if needed, and, upon CMMI approval, implement Transformation Plan in partnership with Participant Hospitals, SMA, Advisory Council, and other relevant stakeholders
Emergency response planning for future public health emergencies (PHEs), and/or recovery from COVID-19 PHE
Respond to the evaluator’s data related and other requests
Monitor programmatic and budgetary progress, including submitting required data and progress reports to CMMI in accordance with the Model terms and conditions
Execute and submit to the Project Officer with its NCC application for Performance Period 1 legally enforceable agreements as needed, e.g., business associate agreements (BAAs) between the Lead Organization and the SMA
Performance Periods (6 years)
Update Transformation Plan annually and, upon CMMI approval, implement updated Transformation Plan in partnership with Participant Hospitals, SMA, Advisory Council, and other relevant stakeholders
Convene the Advisory Council at least on a quarterly basis
Manage cooperative agreement funds
Recruit additional Participant Hospitals as necessary
Recruit additional Aligned Payers and work with payers to identify any legislative or statutory changes necessary to implement the
APM
Provide or procure strategic and operational technical assistance, e.g., to support Participant Hospitals, coordinate the Advisory Council, or perform research to identify emerging needs within the Community
Collaborate with the SMA including meeting Medicaid Participation Targets, as described in section A.4.5.3.2. Medicaid Alignment, and ensuring that the Medicaid Needs Assessment, provided in Appendix IX. Medicaid Needs Assessment is updated in accordance with the Model terms and conditions.
Oversee Aligned Payers compliance with the requirements outlined in section A.4.5.3 Multi-payer Alignment
Timing Lead Organization Activities
Emergency response planning for future public health emergencies (PHEs), and/or recovery from COVID-19 PHE
Respond to data related and other requests for the Model evaluation
Monitor the progress of the Model, including submitting required data and progress reports to CMMI in accordance with the Model terms and conditions and assessing the compliance of all other involved parties with CHART program requirements
Manage any close-out activities, if the Model is not continued
Lead Organizations may use cooperative agreement funds to provide technical support to
Participant Hospitals and the SMA through expanding in-house capacity or engaging contractors. Lead Organizations may also use cooperative agreement funds for emergency response planning for future public health emergencies. Lead Organizations may request to receive less cooperative agreement funding in favor of a lower discount factor for their
Participant Hospitals, as discussed in section A.4.5.1. Capitated Payment.
A.4.4. Community Partners
Recognizing that stakeholder engagement is key to effective reform, the Community
Transformation track of the CHART Model requires that Lead Organizations establish an
Advisory Council. Together the Lead Organization and their Advisory Council will forge robust and meaningful partnerships with their Participant Hospitals and SMA.
A.4.4.1. Advisory Council
To ensure that health care delivery system redesign strategies reflect the Community’s needs and goals, Lead Organizations are required to assemble an Advisory Council. The Advisory
Council will represent the Community’s perspective and collectively advise the Lead
Organization as they carry out their required activities (described in Table 2. Funded Activities for Lead Organizations). A few key activities the Advisory Council will advise on include, but are not limited to, developing and updating Transformation Plans, hospital and payer recruitment, developing arrangements with payers governing APM alignment and data-sharing, monitoring the progress of the Model, and identifying any necessary changes. The Advisory Council will not manage the Lead Organization or Participant Hospitals. The Advisory Council will not be responsible for management and oversight of Cooperative Agreement funds.
Lead Organizations must convene Advisory Councils at least quarterly. Advisory Councils should encompass a variety of perspectives and reflect the Community’s needs. While the specific membership of the Advisory Council will differ by Community, it must include the following representatives:
1. The SMA (if the Lead Organization is not the SMA) even if the SMA is physically located outside of the Community.
2. At least one Participant Hospital (see section A.4.4.2. Participant Hospitals for definition).
3. At least one Aligned Payer (if the Lead Organization has recruited any commercial payers) see section A.4.5.3. Multi-payer Alignment for definition.
4. At least one beneficiary or unpaid caregiver.
Furthermore, the Advisory Council must include a representative from at least three distinct entities from the following list:
1. A primary care provider, such as a Federally Qualified Health Center (FQHC), Rural
Health Clinic (RHC), or physician group practice.
2. A health care provider of substance use disorder treatment and/or mental health services.
3. An additional Participant Hospital.
4. The State Office of Rural Health.
5. An additional Aligned Payer.
6. A community stakeholder group, such as a rural patient advocacy group, Area Agency on Aging, or faith- and community-based organizations.
7. A long-term care facility (e.g. nursing home), home health provider, or hospice provider.
8. An Indian Health Service (IHS) or Tribal health provider or Federally recognized Tribe or
Tribal organization.
9. The U.S. Department of Veteran’s Affairs (VA).
The Lead Organization may include additional representatives from organizations or governmental entities not included in the list above. To be eligible to serve on the Advisory
Council an organization must provide health care services, or services that address health-related social needs, to Community residents. An eligible governmental entity must have jurisdictions that encompass the Community’s parameters. For example, Lead Organizations may consider inviting county governments, and state or local public health departments to join the Advisory Council.
Individual Advisory Council representatives do not need to reside or work within the
Community. However, each organization represented on the Advisory Council must have a presence within the Community or have a contractual arrangement with a health care provider that furnishes Eligible Hospital Services to beneficiaries living in the Community. For the purposes of this NOFO, any organization that advocates for, provides services to, or otherwise serves beneficiaries within a Community, is considered to have a presence within the
Community.
A.4.4.2. Participant Hospitals
Lead Organizations will be expected to recruit Participant Hospitals for the Community
Transformation Track APM. Each Participant Hospital, identified by its CMS Certification
Number (CCN), must be an acute care hospital (defined as a “subsection (d) hospital” in section
1886(d)(1)(B) of the Act) or CAH that either:
1. Is physically located within the Community and receives at least 20% of its Medicare FFS revenue from Eligible Hospital Services provided to residents of the Community; or
2. Is physically located inside or outside of the Community and is responsible for at least
20% of Medicare expenditures for Eligible Hospital Services provided to residents of the
Community.
All other types of health care facilities are ineligible to be Participant Hospitals. In the event that a hospital system has multiple inpatient campuses and outpatient locations, each inpatient campus and outpatient location will be considered a distinct Participant Hospital as long as it separately meets the eligibility criteria in this section.
Subject to CMS approval, Participant Hospitals may simultaneously participate in the
Community Transformation Track and other Medicare value-based programs, models or demonstrations. If a Participant Hospital participates in a Medicare program, demonstration or model, CMS may, in its sole discretion, make adjustments to the Participant Hospital’s
Capitated Payment Amount (CPA) to avoid duplicative accounting of, and payment or penalties for, amounts received by the Participant Hospital under such Medicare program, demonstration, or model.
Lead Organizations must ensure that each Participant Hospital signs a Participation Agreement with CMMI committing the Participant Hospital to, among other things, (1) assume accountability for hospital expenditures (as specified in Appendix XI: CPA Financial
Methodology) for the Medicare beneficiaries they serve that reside in the Community for the full duration of each Performance Period; (2) implement the activities outlined in the
Transformation Plan, as applicable; and (3) report necessary quality and other data to CMMI.
Lead Organizations, as the named CHART award recipients, will be responsible for ensuring that
Participant Hospitals execute certain key model activities to be outlined in forthcoming
Participation Agreements and in alignment with the activities described in Table 2. Funded
Activities for Lead Organizations.
To ensure their eligibility to participate in CHART, Participant Hospitals must sign Participation
Agreements with CMMI in either Performance Period 1 or Performance Period 2. CMMI may allow additional opportunities for Participant Hospitals to sign Participation Agreements.
Regardless of when a Participant Hospital signs a Participation Agreement, it will have up to two years to transition back to FFS reimbursement from the effective date of either (1) Model track termination or non-continuation; or (2) termination of the Participant Hospital’s Participation
Agreement. During this transition period, Participant Hospitals may continue to operate under a capitated payment arrangement until fully transitioned.
A.4.4.3. State Medicaid Agency
SMA participation is required under the Community Transformation Track of the CHART Model.
If the Lead Organization is not the SMA, it must partner with the SMA to implement the CHART
Model. The SMA must participate in the Advisory Council and serve as an Aligned Payer (see section A.4.5.3. Multi-payer Alignment). To ensure that the SMA has the capacity to carry out
CHART’s program requirements, the SMA must be a subrecipient of cooperative agreement funding. As a component of the Community Transformation Track application, SMAs must submit a Memorandum of Understanding (MOU) with the potential Lead Organization (see section E.1.2.2.3. Health Care Delivery System Redesign Concept for MOU requirements).
Table 3. SMA Activities
Timing SMA Activities
Pre- Implementation Period (1 year)
Execute and submit to the Lead Organization legally enforceable agreements as needed, including business associate agreements (BAAs)
Participate in the Advisory Council, even if the SMA is located outside of the Community
No later than 45 days after the start of the Pre-Implementation Period, meet with representatives of CMCS to begin designing and implementing any changes to its Medicaid program required to execute CHART financial alignment (see section A.4.5.3. Multi-payer Alignment)
Collaborate with the Lead Organization to submit progress updates on executing CHART financial alignment (including a timeline agreed upon by the state and CMCS) as an appendix to Quarterly Progress Reports (QPRs) (see section F.5. Reporting)
Performance Periods (6 years)
Participate in the Advisory Council, even if the SMA is located outside of the Community
Collaborate with the Lead Organization to submit progress updates on executing CHART financial alignment (including a timeline agreed upon by the state and CMCS) as an appendix to Quarterly Progress Reports (QPRs) (see section F.5. Reporting)
Timing SMA Activities
Align its Medicaid program with the Community Transformation Track APM (see section A.4.5. Value-Based Payment), including receipt of CMS approval of State Plan Amendments (SPA) and/or 1115(a) demonstration application(s) as needed and, if applicable, working with managed care plans to support APM implementation
Meet Medicaid Participation Targets, as discussed in section A.4.5.3.2. Medicaid Alignment below
The SMA must comply with all data and reporting requirements of the Model, including accurate and timely submission of T-MSIS data (see section F.5.3. Evaluation), and establishing information sharing arrangements and infrastructure
The Medicaid elements of the Model shall operate consistent with existing Medicaid laws and regulations. Acceptance of a Lead Organization into the CHART Model does not constitute approval of any changes to a state’s Medicaid program. Information included in a CHART Model application will be used solely for the purpose of application review for the CHART Model and does not represent a formal request for a State Plan Amendment or 1115(a) demonstration approval on the part of the state, nor a commitment to such approval on the part of CMS.
States shall submit those requests through the existing CMS processes. The SMA will not be permitted to claim federal financial participation (FFP) for administrative activities for which the
SMA receives cooperative agreement funding through the Model to prevent the duplication of funding by CMS.
Upon award, CMMI will help SMAs and Lead Organizations navigate modifications to their state’s Medicaid authorities, if and as needed, to carry out their Transformation Plan. CMMI will work with the Center for Medicaid and CHIP Services (CMCS) to maximize process efficiency for reviewing proposed Medicaid State Plan Amendments (SPAs) and Medicaid waivers. CMMI, in collaboration with CMCS, will begin working with SMAs and Lead Organizations early in the process of developing their Transformation Plans, in order to quickly identify what Medicaid
SPA(s) or waiver(s) might be necessary. See Appendix IX. Medicaid Needs Assessment for information on the pathways available to SMAs to implement the Community Transformation
Track APM.
A.4.5. Value-Based Payment
The capitated payment arrangement in the Community Transformation Track is designed to establish the financial flexibility necessary for Participant Hospitals to engage in health care delivery system redesign activities outlined in Transformation Plans. This APM offers a predictable and stable revenue stream, which mitigates financial instability in rural hospitals and improves their capacity to weather volatility. In particular, methodology will incorporate adjustments 1) for service line changes and 2) exogenous factors (i.e., Public Health
Emergencies). When Participant Hospitals’ revenue is no longer predicated on realized volumes, they will be able to focus on more transformational and collaborative strategies, such as converting to a rural emergency medical center or reconfiguring service lines across multiple
Participant Hospitals (e.g., one hospital shuts down an orthopedic line but refers volume to a neighboring hospital who has a larger and higher quality orthopedic program). In contrast to
FFS incentives to grow volumes, this APM creates an incentive to reduce potentially avoidable utilization, prevent readmissions, and reduce hospital lengths of stay as appropriate. Participant
Hospitals will be able to keep the savings that are generated through these reductions.
Moreover, discounts applied to the Participant Hospitals’ CPAs would secure first dollar savings for Medicare, Medicaid, and Aligned Payers, as described below. For purposes of the Quality
Payment Program, the Community Transformation Track is not an Advanced APM or a MIPS
APM.
A.4.5.1. Capitated Payment
This section provides a description of the financial methodology CMMI will use to calculate the
Capitated Payment Amount (CPA) for each Participant Hospital. CMMI will calculate CPAs, not
Lead Organizations. The CPA financial methodology is included in…
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