NC Medicaid AMH Tier 3 Glide Path Payments
By Joy Key, MBA
North Carolina’s anticipated transformation to the Medicaid Managed Care program, anchored by the Advanced Medical Home (AMH) model, has exciting potential to improve whole-person health and access to care for a large portion of the state’s most vulnerable population. Much of the design and delivery of the 3-tiered AMH system will be the responsibility of local primary care providers (PCPs) and care team members. However, as many primary care providers are realizing, there are substantial challenges in meeting the requirements of the AMH program at the Tier 3 level.
Practices that began AMH readiness activities in 2019 quickly recognized that the start-up infrastructure required to satisfy Tier 3 represents significant investments in cost and effort. Tier 3 Data and Analytics requirements challenge the average practice’s capabilities both in complexity and application. Historically, Medicaid PCPs were not responsible for secure ingestion of large data files, bandwidth, hardware specifications, or maintenance activities. Nor did these providers typically employ IT specialists with this expertise. Further, typical practice EHRs are primarily clinical documentation systems, and not necessarily designed to reconcile large patient empanelment and claims files or to risk stratify full populations. In addition to Data and Analytics, Tier 3 Care Management requirements present a hurdle in the upfront costs associated with hiring and onboarding a full, multidisciplinary Care Management team to carry out comprehensive health assessments and whole-person care management activities.
During the nearly year-long Medicaid Managed Care suspension, NC DHHS took provider and Prepaid Health Plan (PHP) feedback and began to make some adjustments to the AMH Tier 3 program. Details of several improvements are still being reconciled and will be announced in coming months. One of the first, and perhaps most positive and impactful, changes NC Medicaid announced in November is a Glide Path Payment program that will help defray some of the initial costs for building Tier 3 infrastructure. To qualify, Tier 3 practices must:
1) Attest to Tier 3 AMH status in NCTracks,
2) Execute Tier 3 contracts with at least two PHPs,
3) Complete end-to-end data testing with those PHPs, and
4) Attest in NCTracks that conditions 2 and 3 have been accomplished.
There are three Opportunity Periods for Glide Path Payments – April, May and June 2021. Direct payments of $8.51 PMPM will flow to practices through NCTracks for each Opportunity Period that they meet all of the above conditions. NC Medicaid hopes that the potential to receive $8.51 PMPM for up to three months will incentivize practices to renew their efforts in meeting Tier 3 requirements now, well in advance of Medicaid Managed Care launch on July 1, 2021. Comprehensive preparation and readiness is critical to ensure the most appropriate and effective care management will be available for Medicaid beneficiaries as soon as Medicaid Managed Care launches. This also means, however, that there will not be any ‘hold harmless” or grace period for AMH Tier 3s to ramp up services to meet AMH program requirements once Medicaid Managed Care goes live; the expectation instead is that PCPs accepting Glide Path Payments will be ready to effectively operate in accordance with the Tier 3 standards implemented and rehearsed during the Glide Path environment.
There will be more information to come regarding other AMH program changes and improvements prior to launch. Stay tuned for more announcements and updates from Emtiro Health about NC Medicaid’s transition to Managed Care. Meanwhile, if you have questions or concerns about how to best position your practice for success in Medicaid Managed Care, please contact info@emtirohealth.org.