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HMA can help develop and operate PACE programs

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The vast majority of hospitalizations are among patients 65 years and older due to their comorbid chronic illnesses and their requirement for age-appropriate care management. While the aging population increases, nursing home availability and state funding for home-and community-based services have decreased. As a result, the Centers for Medicare and Medicaid Services (CMS) care model Program of All-Inclusive Care for the Elderly (PACE), has boosted growth.

A program aimed at keeping low-income older adults living in the community and out of nursing homes, PACE has been a safe haven for many. Currently offered in 32 states, the program provides home care, prescriptions, meals, and transportation to participants.

The local PACE centers also bring enrollees together to socialize and receive a variety of medical services. Many PACE providers have reported high satisfaction rates among participants. Further, a 2021 report by the Health and Human Services Department found PACE enrollees were significantly less likely to be hospitalized, use emergency departments, or be referred to nursing homes compared to Medicare Advantage members.

Our clients

HMA works with national and state associations, managed care organizations, delivery systems, federal and state public health programs, as well as interested and existing PACE programs to support the promotion and continued improvement of the PACE model. Having led PACE programs, managed care organizations, delivery systems, and federal and state public health programs, the HMA team of multidisciplinary experts is skilled in PACE program design, strategy, growth, and operations. We have direct experience working in and with PACE organizations in policy, application processes, and operational readiness, day-to-day operations, and audit preparation and response.

How HMA can help:

HMA’s team can help organizations strategically identify, plan, and implement the development of a new PACE. HMA’s experts are experienced in leading an organization through the strategic planning processes, educating and orientating an interested sponsor organization in their PACE market of interest, and all of the variables, including the desired PACE service areas, federal and state waivers and licensure requirements, and restrictions, the state, and federal application timelines and processes, and pre- and post-implementation processes and as well as ongoing business operations.

The state and federal application process involves multiple steps and can feel daunting. HMA is well versed in these processes and has assisted many PACE programs across the county complete these applications. HMA will work with you side by side to navigate all of the application requirements including completing and submitting the Notification of Intent to Apply (NOIA), Navigating and Working with State Agencies, and completing the CMS Application.

Although many states operate in similar ways, there are nuances that make each a bit different. HMA consultants have worked with many state agencies across the country, both in states with PACE programs and states without. Whether your state(s) have existing PACE programs, or you are looking to be the first one in the state, HMA has the experience and expertise to help navigate those state-by-state differences. Our PACE team includes previous state Medicaid and federal leaders, providing valuable contacts and knowledge within the state systems.

Achieving performance targets requires advanced systems of care delivery and agile information technology tools for real-time monitoring and managing populations and participants. Effective operating and reporting systems are critical to the success of PACE organizations’ operations. HMA has evaluated system requirements for PACE and can help you identify, select, and implement operating processes and systems. To optimize operations efficiency, we also offer solutions for tracking and managing revenue, participant care costs, productivity, and downstream payments. We can also work to implement telehealth and remote patient monitoring technologies.

Contracting with specialty and ancillary healthcare providers along the continuum of care will be increasingly critical for managing participant care, outcomes, and costs under the PACE model. We can assess the scope and effectiveness of current contractual relationships, including contract language review, reimbursement, reporting requirements, and other elements critical to compliance and operational compliance and success, across a wide range of healthcare and social service providers.

HMA has extensive policy experience with the legislative requirements that govern PACE at both the state and federal level. We can help evaluate the impact of new requirements or legislation to inform your position with regulators. In addition, HMA team members have existing relationships with the National PACE Association as well as various state PACE Associations.

HMA experts are experienced and are well versed in providing data analytic services to both prospective and fully operational PACE programs. Using a full analytics suite, our experts can help with Part D needs including Bid preparation and Part D Reconciliations. Additionally, we can assist organizations with risk adjustment operations and support, forecasting, market analysis, vendor auditing, and strategic support. 

HMA is available to help organizations develop PACE capabilities from concept to implementation and beyond, including post-implementation and ongoing PACE operations. 

Contact our experts:

Debby McNamara

Debby McNamara

Associate Principal

Don Novo

Don Novo

Managing Principal

Jason Pettry

Jason Pettry

Senior Consultant


SAMHSA’s next chapter: priorities, programs, and possibilities

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The prospect of new leadership due to a presidential election brings with it the potential for significant shifts in priorities, policies, and programs within federal agencies. The Substance Abuse and Mental Health Services Administration (SAMHSA) plays an increasingly critical role in shaping the nation’s mental health and substance use disorder services in the United States. Mental health and the opioid crisis are a salient political issue that will receive some attention on the campaign trail, but candidates are unlikely to detail the specifics on how the rhetoric becomes reality.

SAMHSA’s budget could see adjustments, channeling resources toward initiatives that align with the new administration’s vision. This could mean increased funding for specific programs deemed critical under the new leadership and decreases for other programs. Any major shifts in funding will require the support of Congress. Also possible with new leadership are changes to programmatic approaches that revolve around the introduction of novel interventions, expansion of access to treatments, and addressing emerging challenges such as the opioid crisis with renewed vigor.

The intersection of technology and mental health is likely to receive heightened attention. Telehealth expansions, digital tools for prevention and intervention, and data-driven innovations may become focal points of SAMHSA’s strategy.

As SAMHSA adapts to new leadership, the opportunity arises to forge innovative pathways toward improved mental health outcomes and enhanced support for individuals and communities affected by substance use disorders. By embracing whatever change may come, SAMHSA can continue its vital mission of promoting behavioral health and resilience across the nation. The results of the 2024 election will have a significant impact on federal mental health policy in the coming years; DC Direct subscribers get a steady stream of insight to stay on top of what’s coming next.


Takeaways from the ensuring access to Medicaid services final rule

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This week’s second In Focus section delves into the Ensuring Access to Medicaid Services final rule. The Centers for Medicare & Medicaid Services (CMS) published the access rule May 10, 2024, alongside the similarly significant Medicaid managed care final rule. The two rules include new flexibilities and requirements aimed at enhancing accountability for improving access and quality in Medicaid and the Children’s Health Insurance Program (CHIP) across the fee-for-service (FFS) and managed care delivery systems and provide targeted regulatory flexibility in support of this goal.   

Five Takeaways from the CMS Medicaid Managed Care Final Rule, which Health Management Associates, Inc. (HMA), published April 24, 2024, outlined key issues and implications that CMS advanced in the Medicaid managed care program. The Ensuring Access to Medicaid Services final rule, meanwhile, focuses on the following:   

  • Payment adequacy for direct care workers (80/20 rule) 
  • The role of self-direction and the 80/20 rule 
  • Establishment of a pathway to national benchmarking of Medicaid rates   
  • Potential impacts of the rule on programs that serve individuals with dual eligibility 


The Ensuring Access to Medicaid Services finalized policies are designed to create an updated federal framework for Medicaid’s home and community-based services (HCBS) programs. These changes come at a pivotal time, as states are facing workforce shortages, particularly among HCBS direct care workers (DCWs). Table 1 provides an overview of several significant final policies. 

Table 1. Ensuring Access to Medicaid Services: Overview of Final Rule Policies 

Below HMA reviews several key questions we are fielding regarding the impact of the rule.  

Ensuring Payment Adequacy: How will states demonstrate that 80 percent of Medicaid payments go to direct care workers?  

The final rule requires at least 80 percent of Medicaid payments be spent on compensation for DCWs workers, including homemaker, home health aide, and personal care services. In response to public comment, CMS adjusted the final rule to include some employer costs in the 80 percent calculation.  

Recognizing it will take substantial time for providers to establish the necessary systems, data collection tools, and processes to collect the required information to report to states, CMS is providing states six years to implement the HCBS Payment Adequacy policy, and four years for reporting requirements. States and providers must ensure that that they are prepared to meet the payment adequacy requirements in the final rule. Being successful will require collaboration between states and providers, investments in systems, and analysis of – and potentially changes to – reimbursement levels.  

How does the 80/20 rule apply to self-directed care?  

CMS finalized its proposal to require that at least 80 percent of all payments for homemaker, home health aide, and personal care services in HCBS programs, including managed care programs, be spent on compensation for DCWs. In a change from its proposed policy, CMS limits the 80/20 compensation mandate to certain types of self-directed models. Specifically, the 80/20 rule will apply to models in which the beneficiary directing services does not set the payment rate for the worker, such as Agency with Choice and other self-directed models that use a fiscal intermediary or fiscal employer agent, in both managed care and FFS delivery systems. The compensation rule does not apply to self-directed models in which the beneficiary sets the rates paid to workers.  

CMS will hold states accountable for compliance with the 80/20 rule, regardless of whether their HCBS are delivered through an FFS delivery system, managed care delivery system, or both. States will need to determine an approach to track compliance with the minimum performance requirement at the provider level, not the managed care plan level. States and managed care plans should collaborate to determine their respective roles in activities such as the data collection and mandatory reporting, and they should continue to seek and monitor clarifying guidance from CMS. 

How will the Ensuring Access final rule affect national benchmarks in Medicaid rates? State Medicaid programs have many nuances that make it difficult to obtain applicable comparison data and best practices. Beginning July 1, 2026, the final rule requires that states publish their payment rates, specifically the average hourly Medicaid FFS fee schedule payment rates, separately identified for payments made to individual providers and provider agencies, if the rates vary. States also must conduct a comparative analysis of their base Medicaid FFS fee schedule payment rates with the Medicare non-facility payment rate. CMS does not, however, require that states change their payment rates based on the comparative analysis.  

Payment rate transparency publications, comparative payment rate analyses, and payment rate disclosures present opportunities for states, MCOs, and providers to assess the adequacy of payment rates and their impact on access to services. The forthcoming data also will help federal and state level policymakers in their efforts to improve quality, access, and affordability. States will need to do baseline assessments comparing Medicaid and Medicare rates. States, managed care plans, and providers should monitor for CMS sub-regulatory guidance, including hypothetical examples of the service codes that would be subject to the comparative payment rate analysis.  

Does the final rule affect integrated models of care for people who are dually eligible for Medicaid and Medicare? CMS finalizes policies that will have a variable impact on states and individuals dually eligible for Medicare and Medicaid because of differences in state approaches to integrated care for this population. For example, the new grievance system policies apply differently depending on the level of integration the state requires of Medicare Advantage (MA) dual-eligible special needs plans (D-SNPs) programs. Like grievance systems, states, providers, and MCOs should monitor how states address the final rules for critical incidents for individuals with dual eligibility when a Medicaid managed care plan is unable to access Medicare data.  

CMS intends to provide additional sub-regulatory guidance and technical assistance to support implementation of policies that affect dually eligible individuals. States should verify their access to and readiness to use Medicare data related to the new requirements, and seek technical assistance to maximize use of these data for individuals enrolled in non-integrated D-SNPs. Commentors have also asked how the changes to the HCBS quality measure set may work in programs for dually eligible members.  

Connect with Us  

HMA is ready to support your efforts to understand and take action to account for the Ensuring Access to Medicaid Services final rule’s effects on your state’s or organization’s strategy and operations. Our experts are developing policies and procedures at the intersection of the access and managed care final rules. Please contact Susan McGeehan, Dari Pogach, and Patrick Tigue to connect with our expert team members on this vital set of issues.


HMA opens registration for fall conference: Unlocking Solutions in Medicaid, Medicare, and Marketplace

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Unlock Solutions in Medicaid, Medicare, and the Marketplace at HMA’s Fall Conference, October 7−9 

This week, we preview what to expect at the 7th annual Health Management Associates, Inc. (HMA) Fall Conference “Unlocking Solutions in Medicaid, Medicare, and Marketplace,” October 7−9, 2024, at the Marriott Marquis Chicago, IL. Learn more about our Keynote Speaker and take advantage of our Early Bird Registration

Keynote Speaker Announced 

We are pleased to announce our Keynote Speaker will be Darshak Sanghavi, MD, program manager at the Advanced Research Projects Agency for Health (ARPA-H)—a newly created multibillion dollar federal agency tasked with developing health programs that are “so bold no one else, not even the private sector, is willing to give them a chance.” His talk, “Unlocking Health Solutions through Innovation,” will highlight the innovative collaborations and projects ARPA-H is advancing. A trained clinician who has served in high level public and private sector advisory roles, Dr. Sanghavi will discuss how this new wave of research and innovations is changing how we think about healthcare’s challenges and will address why the agency is so important at this time. He will highlight ARPA-H investments and commitments and the timeline for impact, including how healthcare systems and states should be thinking about ARPA-H funded innovations and preparing for scaling breakthroughs that improve outcomes.  

Before joining ARPA-H, Dr. Sanghavi was global chief medical and clinical operating officer for Babylon, the global end-to-end digital healthcare provider serving more than a dozen countries and 24 million-plus people, with the mission of bringing “affordable and accessible healthcare to everyone on earth.” He also has served in senior roles at UnitedHealthcare’s Medicare & Retirement, OptumLabs, the R&D hub of UnitedHealth Group, and in the Obama Administration as the Director of Preventive and Population Health at the Center for Medicare and Medicaid Innovation, where he directed the development of large pilot programs designed to improve the nation’s healthcare costs and quality. He is an award-winning medical educator, who has worked in medical settings around the world. He will draw on these diverse experiences to inspire and challenge attendees to unlock solutions to some of our healthcare system’s most complex issues. 

Network with Leaders in Healthcare 

This is an important moment for ever-changing publicly sponsored healthcare programs like Medicaid, Medicare, and the Marketplace, with greater focus on value and federal initiatives that encourage improved health equity, affordability, quality, and outcomes. Don’t miss out on this opportunity to form new partnerships as you dig into today’s urgent issues and immerse yourself in insightful discussions, networking opportunities, and engaging workshops on the new Medicaid managed care rule, applications for AI in healthcare, approaches to meet rural workforce needs, value-based care contracting, and insights from state Medicaid services.  

Preconference tactical workshops will focus on exclusive tools, insights, and strategies to guide program design, navigate new regulatory frameworks, and advance value-based care. HMA’s premier national conference plenary and breakout sessions will focus on the landscape for innovation in healthcare, emerging service delivery models, and growth strategies in pursuit of improved value, quality, and better outcomes. 

Who should attend? 

Executives and leaders from federal, state, and local government agencies, health plans, payers, managed care, hospitals and health systems, provider and provider enablement organizations, community-based organizations, IT companies, life sciences organizations, investment firms, foundations, and associations. 

Brief & Report

New HMA report using VRDC data analyzes hip fracture outcomes in Dual Eligible population


In this new report, “Answering Questions Using Virtual Research Data Center (VRDC): How using Home and Community-Based Services (HCBS) Impacts Hip Fracture Outcomes“, HMA is now using Centers for Medicare & Medicaid Services (CMS) Virtual Research Data Center (VRDC) to answer important healthcare questions. One contractual obligation for use of CMS data is the release of a publicly available research paper using the dataset, which contains all Medicare fee for service (FFS) and Medicaid FFS and managed care organization (MCO) claims. HMA used the VRDC data to examine the relationship between Long-Term Services and Supports (LTSS) and Home and Community-Based Services (HCBS) on hip fracture outcomes for people who are dually eligible for Medicare and Medicaid benefits. The analysis found that patients who receive HCBS were less likely to incur a future inpatient stay. The report and data analysis are detailed below.

VRDC Medicare and Medicaid claims data can be used to develop best practices for the healthcare system, looking at patient demographics, including eligibility/enrollment types (including dual-eligibles), race/ethnicity, age, and other critical subgroups to inform equity analyses. These data can be used longitudinally to measure the effect of interventions as well as to inform population health strategies. HMA’s nationally renowned subject matter experts can now incorporate VRDC data analysis and analytics into their recommendations to help your organization solve your toughest challenges.


The 2024 Presidential Election and its long-term impact on Medicaid

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The prospect of new leadership due to a presidential election brings with it the potential for significant shifts in priorities, policies, and programs within federal agencies. Medicaid now provides healthcare coverage for more than 84 million Americans. Since 2010, Medicaid has been subject to significant federal policy changes, starting with expansion as part of the Affordable Care Act, pandemic-related continuous eligibility provisions, expanded coverage for postpartum women, and just recently updated rules for managed care plans. The 2024 election will have a significant impact on Medicaid in the coming years, although you won’t hear much about it on the campaign trail (but our DC Direct subscribers get a steady stream of insight to stay on top of what’s coming next).

Medicaid’s political salience has been quiet but steadily increasing since 2010, with now 41 states (including DC) having expanded access, changing the political narrative about the program. Medicaid coverage churn due to the unwinding of the pandemic related continuing-coverage provisions has been politically fraught for governors and legislatures, even bringing some states like Mississippi to finally consider the expansion opportunity to improve stability of coverage.

States each have their own approach to designing Medicaid coverage, but federal rules set the parameters within which they choose how to maintain access and quality of healthcare for low-income individuals and families.  New CMS rules are requiring require more from managed care plans who contract to administer Medicaid in many states, increasing network adequacy, quality measurement standards, consumer protections and tailored approaches for long-term services and supports. These changes will shape the future of procurements for managed care services.

The election is very likely to touch on broad issues of affordability and equity, which are relevant to all healthcare programs but especially to Medicaid. Current policy priorities that center on equity have resulted in program design features that can impact the social determinants of health, including initiatives to address housing insecurity, food access, and mental health services. Increasingly these concerns have been bipartisan, although the proposed approaches will differ based on who is in charge.

Changes in national leadership – whether at CMS, HHS, or in the White House – will inevitably result in changes to the Medicaid program that impacts states and the agencies that serve the millions of Americans who rely on the program for essential healthcare services. Our Leavitt Partners colleagues provide regular intelligence on all the federal activity in D.C. that impacts Medicaid and other state health programs. Learn more about DC Direct and how this steady stream of insight can help inform your strategic decisions.

HMA News

New HMA white paper examines Medicare’s reimbursement system for physicians’ services

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Researchers explore its history, reasons behind calls for reform, and provide recommendations for improvements

Today, HMA released a new white paper, “Medicare Physician Fee Schedule Reform: Structural Topics and Recommendations to Strengthen the System for the Future.” It provides an in-depth analysis of the Medicare Physician Fee Schedule, including the history of its implementation, stakeholder perspectives on reform, major structural issues, and recommendations for improving the $90-plus billion payment system.

Recent years have witnessed a growing bipartisan call to reform how Medicare reimburses for physician and other health professional services. A wide array of stakeholders assert that the current system—the Medicare Physician Fee Schedule (PFS)—is misaligned with today’s practice patterns and market dynamics. Many constituencies maintain that the PFS is insufficiently updated, embeds known pricing distortions, and does not appropriately effectuate value-based care principles. Although a considerable number of legislative and regulatory changes have been implemented to refine and modernize the system, the PFS has never been subject to a major statutory overhaul that would comprehensively address pressing issues. 

HMA studied these issues with support from Arnold Ventures in “Medicare Physician Fee Schedule Reform: Structural Topics and Recommendations to Strengthen the System for the Future.” HMA’s white paper is an accessible primer on the PFS and key moments that led to the current policy situation. The white paper describes structural topics in the PFS that raise concern or prompt calls for change, provides context on the history and progress of the payment system and highlights stakeholder perspectives on reform.

For accessible background and context on the PFS and why the stakeholder community is calling for reforms to the fee schedule, click below.

View an electronic timeline of key policy developments and highlights of topics related to the PFS since implementation in 1992 here.

About HMA

Founded in 1985, HMA is an independent, national research and consulting firm specializing in healthcare and human services policy, programs, financing, and evaluation. Clients include government, public and private providers, health systems, health plans, community-based organizations, institutional investors, foundations, and associations. Leavitt Partners, an HMA Company has been at the forefront of navigating change in healthcare for over a decade and works at the intersection of government and health care, helping clients stay one step ahead of the influences impacting the industry, including economic, market, delivery system, public policy, and political developments. HMA has offices in more than 30 locations across the country and over 700 multidisciplinary consultants coast to coast. Learn more about HMA at, or on LinkedIn and X.

About Arnold Ventures

Arnold Ventures is a philanthropy dedicated to tackling some of the most pressing problems in the United States. It is a team of more than 120 subject-matter experts headquartered in Houston with offices in New York and Washington, D.C. It works in five key issue areas: Criminal Justice, Education, Health, Infrastructure, and Public Finance. Its work is guided by evidence-based policy, research, and advocacy.

Brief & Report

Medicare Physician Fee Schedule Reform: Structural Topics and Recommendations to Strengthen the System for the Future


Recent years have witnessed a growing bipartisan call to reform how Medicare reimburses for physician and other health professional services. Stakeholders assert that the current system—the Medicare Physician Fee Schedule (PFS)—is misaligned to today’s practice patterns and market dynamics. Many constituencies maintain that the current approach is insufficiently updated, embeds known pricing distortions, and does not appropriately effectuate value-based care principles, such as providing cost-conscious, high-quality care that prioritizes performance measurement and patient experience. Calls for reform are further prompted by increasing concern about the viability of independent physician practices, including the implications of consolidation and private equity acquisition of physician offices. Finding a workable comprehensive solution to updating physician payments is an uphill battle stymied by the significant cost of doing so, competing stakeholder positions, and the complexities of restructuring payment.

The original design of the Medicare PFS, still in use today, is based on the resources typically needed to provide services to patients. First implemented in 1992, the PFS is a fee-for-service (FFS) system of payment premised on the idea that services should be separately valued in relation to each other. This requires information on the effort and costs incurred to perform those services and how those variables change over time. The Centers for Medicare & Medicaid Services’ (CMS’s) efforts to update data used to set rates in the required budget neutral manner often result in system instability and may take years to fully implement due to concerns about redistribution. These innate vulnerabilities have been compounded by three decades of policy decisions, statutory changes, and advancements in care delivery.

While established metrics suggest that physicians’ participation in the Medicare program and beneficiary access is currently adequate, the Medicare Payment Advisory Commission (MedPAC) raises concerns that beneficiaries may experience more access to care barriers moving forward. For the past two years, MedPAC has recommended physician payment updates based on changing economic conditions, as well as additional “safety net” payments to physicians treating low-income beneficiaries. Reducing health disparities and improving the foundation of care is a top priority for many in this country, and payment reform within the PFS and more broadly that expands technology while also investing in person-centered, community-oriented care (especially for populations that are underserved and/or living with multiple chronic conditions) is central to that cause.

As robust policy discussions are taking place to explore these issues and identify solutions, Arnold Ventures engaged HMA to provide accessible background and context on the PFS for people who may be unfamiliar with the payment system, including a review of how the stakeholder community got to the point of needing to “fix” the fee schedule. Through a thorough assessment of the most pressing policy and payment concerns, we identified several key structural issues within the physician fee schedule that should be considered and balanced when making policy changes to the payment system.


Succeeding in the world of value-based payments: assess your organization’s VBP readiness

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In the ever-evolving landscape of healthcare, the shift towards value-based care (VBC) has emerged as a transformative force, promising improved outcomes, reduced costs, and enhanced patient experiences. While the benefits of VBC are clear, the path to implementation can be complex and challenging, particularly for behavioral health (BH) providers. In this blog post, we delve into the significance of assessing readiness for VBC and value-based payment (VBP) systems, with a specific focus on BH providers, and why it serves as a crucial step towards success.

Behavioral health plays a pivotal role in holistic patient care, addressing mental health and substance use disorders that significantly impact overall well-being. However, traditional fee-for-service models often inadequately incentivize preventive and coordinated care, leading to fragmented services and suboptimal outcomes. Recognizing this gap, the transition to VBC offers a promising avenue to realign incentives, improve care coordination, and enhance patient outcomes in the realm of behavioral health.

Insights from the HMA Spring Workshop

In March 2024, HMA hosted a workshop on value-based care, (you can read more of the key takeaways here). A consensus emerged on the indispensable role of data and technology in driving informed decision-making. Dr. Katie Kaney’s keynote address on innovative approaches to holistic care metrics resonated with attendees, highlighting the need to move beyond conventional measurements towards a comprehensive understanding of patient well-being.

A pivotal aspect of VBC lies in the collaborative effort between payers and providers to align measures and incentives while ensuring these measures hold significance for all stakeholders, including payers, providers, and patients. The conversations with attendees on Empowering Care Delivery through Tangible Measures underscored the imperative of clinician involvement in outcome measurement establishment. We discussed the importance of meaningful measurement for state-level initiatives and local strategies, all aimed at achieving better outcomes for our communities.

The Importance of Readiness Assessment

Embarking on the journey towards VBC demands a comprehensive understanding of organizational strengths, challenges, and readiness to embrace change. As we navigate the transition to value-based care, understanding where your organization stands is key. This is where readiness assessment tools play a pivotal role. By systematically evaluating various aspects of organizational preparedness, such as infrastructure, data capabilities, care delivery models, and cultural readiness, organizations can identify areas for improvement and tailor strategies to navigate the transition effectively.

Tailoring Strategies for Success

Assessing readiness enables organizations to tailor strategies that align with their unique circumstances and challenges. For instance, organizations lacking robust data infrastructure may prioritize investments in health information technology and analytics capabilities to support population health management and outcome measurement. Similarly, addressing workforce training and cultural transformation can foster a patient-centric approach and promote collaboration across care teams.

Mitigating Risks and Maximizing Opportunities

VBC presents both opportunities and risks for organizations. While it offers incentives for preventive care, care coordination, and improved outcomes, it also requires operational and cultural shifts that may pose challenges. Readiness assessment enables organizations to identify potential risks, such as inadequate data systems, reimbursement uncertainties, or staff resistance, and develop mitigation strategies to address them proactively. Moreover, it empowers organizations to capitalize on opportunities, such as alternative payment models, partnerships with primary care providers, and value-based contracting, to enhance sustainability and growth.

Driving Quality and Equity in Behavioral Health

At its core, VBC embodies a commitment to delivering high-quality, equitable care that addresses the diverse needs of patients. By assessing readiness and embracing VBC principles, BH providers can enhance care delivery, improve outcomes, and reduce disparities in access and quality of care. Furthermore, by integrating behavioral health into broader care delivery models and payment structures, organizations can foster a more holistic approach to health and well-being, promoting resilience and recovery for individuals and communities alike.

Moving Forward with Confidence

As organizations navigate the complexities of VBC, assessing readiness serves as a guiding compass, illuminating the path forward and empowering organizations to embrace change with confidence. By leveraging readiness assessment tools, organizations can identify strengths, address weaknesses, and chart a course towards sustainable, value-driven care delivery. In doing so, they not only enhance their own viability and success but also contribute to a more resilient, equitable healthcare system that prioritizes the well-being of all individuals.

How HMA Can Help

There are many tools online that offer to help organizations determine their readiness for implementing VBC. By using HMA’s new VBP Readiness Assessment tool, you also can gain access to the experts on HMA’s behavioral health and VBC teams. Meticulously crafted to gauge your organization’s preparedness, HMA’s value-based payment readiness assessment surveys six domains of core functions necessary for successful payment reform models.

Taking the survey and receiving one analyzed response is free, but you may find value in contracting with HMA for a more in-depth analysis of your organization.

Assessing readiness for VBC is not merely a preparatory step but a fundamental aspect of organizational transformation. For behavioral health providers, it represents a critical opportunity to reshape care delivery, drive quality and equity, and ultimately, improve the lives of those served. As the healthcare landscape continues to evolve, readiness assessment will remain an indispensable tool for navigating change, fostering innovation, and realizing the full potential of value-based care in behavioral health.


Medicaid Unwinding Check-in: Data Informed Observations to Guide Future Action

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In this week’s In Focus section, HMA Managing Director Matt Powers and Associate Principal Lora Saunders discuss observations and perspectives as we approach completion of the Medicaid unwinding.   


In response to the COVID-19 pandemic, CMS offered states an enhanced federal match in exchange for states pausing Medicaid disenrollments. As a result, Medicaid enrollment increased from around 71 million at the start of the pandemic to more than 92 million in December 2022, when Congress passed a bill to end the “continuous eligibility” provision. States began to resume normal (pre-pandemic) redetermination activities in early 2023—a massive undertaking of attempting to reach and verify eligibility for the then 94 million Medicaid enrollees known as “unwinding.”  

More than 70 percent of the efforts that will precipitate the largest one-year drop in enrollments since the program’s inception in 1965 have been completed. The enrollment reductions to date have been virtually identical to HMA’s aggregate projections, and overall enrollment remains well above pre-pandemic levels. Perhaps most importantly, the Medicaid unwinding has put policymakers in a position to better evaluate how to improve enrollment and redetermination processes going forward.   

Figure 1 summarizes pre-pandemic enrollments, unwinding enrollments, and the projected end of 2024 enrollment. If the current trend holds, national Medicaid enrollment will be approximately 80 million enrollees—down from the 94 million pre-unwinding enrollment peak and nearly 10 million greater than the 71 million pre-pandemic enrollment. 

Our team’s assessment of the status of and data related to the Medicaid unwinding has led us to the following observations: 

  • Arkansas, Iowa, Nebraska, Utah, and West Virginia have completed the redetermination process. More than half of the states are within two months of finishing the process. 
  • The states that saw Medicaid enrollment grow the most under the continuous coverage policy are generally the same ones that are experiencing the greatest enrollment declines during the Medicaid unwinding. 
  • Some larger states—including California, New York, and Texas—have sizeable outstanding redeterminations.   
  • Nationally, more than 70 percent of all Medicaid enrollees have completed the redetermination process.  Figure 2 points out how far along states are with the redetermination process as of late April 2024. 

Medicaid Unwinding: The Road Ahead 

As the Medicaid unwinding process enters its final phase in most states, we are looking back at the experiences and lessons that can be applied to make impactful changes to Medicaid eligibility policies, systems, and procedures. 

Despite the challenges that the pandemic presented, the safety net was tested and responded well. In early 2020, the number of employed Americans decreased from 158 million to 133 million, and unemployment levels quickly reached 15 percent. Many new healthcare policies targeted direct access issues (e.g., financial supports to providers and telehealth regulatory relaxations), whereas the Medicaid continuous coverage requirement was intended to mitigate the effects of the abrupt spike in unemployment and potential effects on healthcare insurance. Table 1 shows how HMA projects national coverage patterns to change by type of coverage from before the pandemic through the end of the Medicaid unwinding. While the number of people with employer-sponsored insurance (ESI) or uninsured remains essentially flat, Medicaid enrollment grows significantly, and marketplace enrollment nearly doubles. Myriad federal and state policy changes contributed to a remarkably stable uninsurance rate during one of the most volatile economic periods in the past century. 

A next question for policymakers is whether, or to what extent, the rate of uninsured people can be sustained or reduced. The broad state adoption of policies to expand postpartum coverage to 12 months from two months and the nationwide January 2024 requirement for states to offer 12 months of continuous Medicaid coverage for children provide a coverage and continuity boost, especially given that nearly 40 million children will benefit from the new law. Other policy levers have the potential to be widely accepted and provide a further incentive to move people who are uninsured toward coverage, more stable insurance products, and more predictable outcomes and costs relative to the inefficiencies and ineffectiveness of non-coverage. 

Pivoting to best practices and making policy changes permanent. Just as the relaxation of relatively rigid telehealth policies has become more accepted, post-Medicaid unwinding will provide a natural opportunity to assess best practices and consider permanent policy changes.    

  • Making Ex Parte Durable Policy.  Evidence suggests that ex parte policies effectively reduce churn. Further refinement of longstanding ex parte policies is within reach. Ensuring ex parte appropriately manages both the complexities of household versus individual eligibility issues and addresses the weaknesses of unreliable member contact information can improve the likelihood that ex parte can effectively serve as durable policy.  
  • Pivoting from Paper to Electronic Communications.  The Medicaid unwinding has seen more partnerships and innovation with state and federal workers, providers, managed care organizations, and consumer advocates, and allowed the increased use of mobile devices for outreach and engagement. Making more deliberate strides to simplify eligibility and move the eligibility platform, patient engagement, and member outreach to more reliable communication methods (e.g., email, text, and member portals rather than paper communication) while adhering to privacy and security requirements is a logical next step.   
  • Continuing to Measure Better. Call abandonment rates, call center wait times, and application processing times—metrics that focused on some of the key challenges to a successful redetermination and timely access to care—received greater attention during the unwinding but were frequently overshadowed by other primary metrics like “disenrollments” and “procedural terminations.” Though disenrollment data and procedural terminations could be used to identify potential areas of concern, their emergence as primary metrics often diverted energy from innovative engagement and redetermination efforts. A focus on contextualized metrics that provide actionable information will support effective oversight and monitoring.

Marketplace growth may be the real story. Throughout the pandemic, marketplace enrollment has steadily increased, jumping nearly 90 percent from 2020 to 2024 and 30 percent from 2023 to 2024, to reach more than 21 million enrollees. Driving the growth in marketplace enrollment are temporarily increased marketplace subsidies and Medicaid unwinding public awareness campaigns.  

  • The marketplaces are proving to be a reliable source of coverage for consumers without health insurance access through ESI or other public programs, particularly in times of significant change such as the Medicaid unwind. With more marketplace enrollees and, therefore, broader risk pools, more health insurers are considering offering marketplace plans and are assessing competitive advantages like lower costs, broader provider networks, and more robust drug formularies. 
  • Figure 3 shows that marketplace growth in non-expansion states is far outpacing marketplace growth in Medicaid expansion states, suggesting that the key elements of the Affordable Care Act have developed deep roots.  

HMA’s experts continue to monitor Medicaid unwinding developments. We are taking a comprehensive approach to assessing lessons learned and opportunities to improve Medicaid as state and stakeholder experiences and data continue to become available over the next two quarters. 

For more information or questions about Medicaid unwinding developments, contact Matt Powers and Lora Saunders.