Comments to DSS opposing increase in PCMH Plus funding for program that didn’t improve quality and increased state costs

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Thank you for this opportunity to oppose this amendment to add an additional $600,000 to the growing costs of PCMH Plus, the experimental new Medicaid shared savings program. The state cannot afford to spend more on this program that, in 2017 its first year, did not improve the quality of care and only increased costs to the state. Despite this poor performance, the program, and the burden on taxpayers, was expanded last year. According to the SPA proposal, costs of the program to the state have risen from $5.57 million in 2017 to $6.6 million this year, if the SPA is approved. It is troubling that the new funds are targeted only to Connecticut’s federally-qualified health centers (FQHCs) which have historically performed poorly in quality and cost measures. Taxpayers cannot afford to continue this experiment.

Our attached analysis of recently released information on the program’s first year performance finds little evidence of quality improvement, and rather than saving the state money, PCMH Plus had significant net costs to taxpayers. For the data, consultants compared the quality and cost of PCMH Plus members’ care with a matched comparison group of Connecticut Medicaid members not in the PCMH Plus program.

  • The cost of care for PCMH Plus members was much higher before implementation of the program and remained significantly higher after
  • PCMH Plus benefitted lower quality, higher cost health systems (ACOs), particularly FQHCs
  • Every ACO, regardless of quality improvement or savings performance was rewarded with a final incentive payment.
  • PCMH Plus payments did not correlate with quality improvement. The highest and lowest quality ACOs were both awarded the same incentive payments per member-months.
  • Outpatient emergency care rates, a vitally important indicator of quality and access to care, was over 30% higher for PCMH Plus ACOs than the comparison group, both before and after implementation
  • Connecticut Medicaid members who get their care at FQHCs have historically had to rely on emergency departments more than other Medicaid members

For almost twenty years, the CT Health Policy Project has worked to improve access to affordable, quality care for every state resident. As independent consumer advocates, we provide policymakers with information and options to improve care while controlling costs. With other independent advocates, the CT Health Policy Project was actively engaged in development of PCMH+. We thank the department for incorporating many of our suggestions to help protect consumers and mitigate the potential harms of shared savings that have happened in other states and in Connecticut’s previous Medicaid Managed Care Program with similar incentives. Those harms include inappropriate denials of necessary care (underservice) and cherry-picking patients for financial reasons (adverse selection). We also appreciate that the department intends to protect underlying policies, such as Person-Centered Medical Homes, Intensive Care Management, and Pay-for-Performance quality initiatives, that have generated nationally-recognized improvements in quality, access and cost savings to the state. Unfortunately, the PCMH Plus experiment has not lived up to expectations.

We urge the state not to increase funding to PCMH Plus and reserve those funds to support ongoing initiatives that proven their worth to both improve the health of Medicaid members and responsibly steward limited tax dollars. Thank you again for this opportunity to comment.

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