Wednesday, February 26, 2020

Homeless Special Needs Plans for People Experiencing Homelessness


·         1CareMore and Aspire Health, Cerritos, California
·         2Stanford University School of Medicine, Stanford, California
·         3LA Care, Los Angeles, California
·         4SNP Alliance, Washington, DC
·         5Boston Healthcare for the Homeless, Boston, Massachusetts
·         6Massachusetts General Hospital, Harvard Medical School, Boston
JAMA. Published online February 13, 2020. doi:10.1001/jama.2019.22376
The US Census Bureau estimated that in 2018, more than 550 000 individuals experienced homelessness on any given day.1 Homelessness is both a recognized cause and a result of health problems. There has been a movement over the past several years to include housing as a health care intervention by several key cities and municipalities, notably, San Francisco, New York, and Los Angeles. Although these programs have had some success with small populations of patients, their reliance on city budgets raises questions about scalability. The creation of a homelessness-focused special needs plan, a type of Medicare Advantage insurance plan aimed at meeting the unique care needs of specific high-need populations, may be an approach through which to sustainably finance health care delivery for homeless individuals.
Special Needs Plans
Special needs plans, first authorized by the Centers for Medicare & Medicaid Services (CMS) in the Medicare Modernization Act of 2003, are not widely known, but are a form of Medicare Advantage plans that have quietly increased in popularity and now include almost 3.2 million patients who are enrolled in Medicare in 734 different plans.2 Individuals are eligible if they are eligible for Medicare and meet criteria for inclusion in a plan type. CMS, sometimes in coordination with state Medicaid agencies, administers these plans in partnership with managed care organizations.
Special needs plans enable specialized benefit designs for particular chronic conditions (eg, end-stage kidney disease, diabetes, heart disease, chronic obstructive pulmonary disease) or for groups of people with specialized health care needs (patients eligible for both Medicare and Medicaid or patients requiring an institutional level of care). Although special needs plans vary widely in their design, organization, and care delivery models, they are characterized by highly focused clinical model requirements, higher degrees of care coordination, and care that is closely tailored to meet the specific needs of the populations served. These plans are regulated by CMS to ensure patients receive care consistent with predesigned standards. For example, diabetes special needs plans offer specialized benefits, physician choices, and drug formularies to optimize care for individuals with diabetes; institutional special needs plans focus on the specific care needs of patients who are homebound; and dual-eligible special needs plans coordinate benefits for patients who are eligible for both Medicare and Medicaid. Select special needs plan types have been associated with less emergency department use, less hospital use, and fewer readmissions.3
The Homeless Special Needs Plan
The homeless population—composed of many individuals who qualify for Medicare because of age or disability or Medicaid because of low income—is growing again after years of decline and is projected to increase over the next decade.4 Special needs plans offer a possible solution to help provide care for the homeless population that is not effectively addressed by traditional health care delivery models.
Homeless individuals enrolled in traditional fee-for-service Medicare and Medicaid are often underserved by a delivery system that is not designed to address their wide range of complex social and behavioral needs.5 Fee-for-service payments result in a focus on addressing the effects of homelessness, not the related underlying mental health, substance use, or economic or social conditions; this care is expensive and suboptimal. Homeless individuals are often cared for by clinicians on the streets or in shelters and require intensive case management and care coordination, including close engagement with local housing authorities, medical care professionals and centers, inpatient facilities, and other programs.6 Fee-for-service Medicare and Medicaid financing is not designed to address homelessness and deliver this type of coordination, despite the best efforts of many well-intentioned homelessness health care delivery organizations. For this reason, the creation of a new approach in the form of a homeless special needs plan that would fully capitate monthly payments to organizations willing to assume full financial risk for the care of homeless individuals may be effective in driving better outcomes and higher degrees of care coordination.
As with other types of special needs plans and Medicare Advantage plans, Medicare Advantage organizations offering homeless special needs plans would need to receive adequately risk-adjusted payments per member per month that reflect the total true cost of caring for patients. Those payments could be used to fund all Medicare Part A, B, and D benefits, including professional services, institutional care expense, and pharmacy benefits. Depending on the design selected, plans could be administered through the Medicare program, Medicaid through Medicaid managed care partners, or through a coordinated model leveraging the infrastructure of both programs.
The specific model of care requirements designed for any medical group that aims to provide medical services for homeless populations might include mobile, community, and street-based medical care delivery; intensive psychiatric and addiction treatment services for patients who need it; management of underlying diseases that may contribute to or be influenced by an individual’s state of homelessness; case management in collaboration with local housing agencies; transportation to and from health care and housing; work to secure safe and stable housing; and, in some cases, respite care. It is likely that delivery organizations that provide homeless special needs plans would include traditional clinicians and centers that provide care for homeless individuals, such as federally qualified health centers; local, state, and federal agencies; and community organizations with experience addressing the needs of homeless individuals.
Suggestions for a Homeless Special Needs Plan Pilot Design
This idea for a homeless special needs plan should first be pilot tested by the Center for Medicare and Medicaid Innovation (CMMI). If the results of the pilot program suggest that the program leads to lower costs for people experiencing homelessness or housing instability; better clinical outcomes; and, ultimately, a lower rate of homelessness, especially for patients whose homelessness is associated with treatable mental illness, addiction, and other debilitating medical conditions, then it could be expanded to the entire Medicare Advantage program.
To test, implement, and scale homeless special needs plans, CMS would need to address several key operational challenges. First, actuaries would need to establish payment adjustments that would adequately account for costs of appropriately providing the range of health care and other services needed by enrollees in a homeless special needs plan. Because current diagnosis-based risk adjusters are unlikely to accurately estimate all of the medical expenditures of homeless individuals, a payment factor should be developed, similar to the frailty adjuster already used, to account for the higher expenditures associated with social determinants and drivers of health.
Second, CMMI would have to derive a definition of homelessness that could easily and effectively be applied. For simplicity, homelessness could be defined as more than 6 months of unstable housing. Verification will be challenging, but there are potential forms of documentation (eg, shelter records, eviction notices) that could be used to establish chronicity. CMMI should also consider defining criteria to identify at-risk beneficiaries to enable health plans to help patients avoid the negative effects of homelessness and partnering with other agencies, such as the US Department of Housing and Urban Development, to help provide financial support, such as subsidies, vouchers, and access to rapid rehousing programs.7 Similarly, it would be necessary to determine if and when a formerly homeless individual who has been supported under a homeless special needs plan is no longer eligible for the plan. To avoid recidivism but maintain cost savings, lifetime eligibility could be considered, but with a stepwise decline in additional risk modifiers to adjust for the expected lower average medical costs once an individual has stable housing.
Third, CMS would have to develop model-of-care requirements that could be consistently applied across the variety of rural and urban geographies in which individuals experiencing homelessness live, but also enable the flexibility to meet local and context-specific needs. Enabling multiple potential design concepts for homeless special needs plans in pilot programs through a CMMI demonstration could help identify the correct long-term guardrails around program definitions.
Fourth, there will need to be flexibility for real experimentation on benefit design regulatory flexibility around issues, such as the medical-loss ratio, to optimally serve this diverse population. Benefits have historically been defined by Medicare Advantage plans independent of the individual’s housing status. Recent flexibility in benefit design to address social determinants of health will be helpful as plans develop appropriate network and benefit designs, but additional flexibility may be needed to establish appropriate solutions.8
Opportunities and Challenges
The homeless special needs plan pilot program should measure total cost of care; quality of health care delivered; and, importantly, reductions in rates of homelessness. To be scalable and meet the requirements of scaling a CMS demonstration, the pilot program would need to deliver on total cost of care savings. Given the transient nature of the homeless population and challenges locating and tracking individuals, the effectiveness of this program may be difficult to measure. There are also reasonable questions about how much social spending should be absorbed by health care budgets. Although the higher levels of interagency coordination enabled by homeless special needs plans, along with more effective management of homelessness-precipitating health conditions, may lead to lower overall public spending, this is an untested question that would have to be answered empirically by a CMMI demonstration.
The current administration has defined addressing homelessness as a key administration priority.9 Homeless special needs plans that are built within the existing regulatory framework guiding special needs plans, or, alternatively, Medicaid,10 offer a potential solution to the health care contributors to homelessness. CMMI should test homeless special needs plan models to determine the extent to which alternative models of health care delivery and financing could help alleviate the growing national challenge of older adults experiencing homelessness and its associated health conditions. This collaborative, multisector approach could hold significant promise to reducing the number of homeless individuals and increasing access to health care and related services through levels of coordination that are otherwise impossible to achieve.
Article Information
Corresponding Author: Sachin H. Jain, MD, MBA, CareMore and Aspire Health, 12900 Park Plaza Dr, Ste 150, Cerritos, CA 90703 (shjain@post.harvard.edu).
Published Online: February 13, 2020. doi:10.1001/jama.2019.22376
Conflict of Interest Disclosures: Dr Jain reported being employed by Anthem, Inc, a national managed care company. No other disclosures were reported.
References
1.Homeless statistics by state. US Interagency Council on Homelessness website. https://www.usich.gov/tools-for-action/map/#fn[]=1400&fn[]=2900&fn[]=6000&fn[]=9900&fn[]=13500. Accessed December 23, 2019.
2.About SNPs. SNP Alliance website. http://snpalliance.org/about-snps-mmps/. Accessed December 23, 2019.
3.McGarry  BE, Grabowski  DC.  Managed care for long-stay nursing home residents: an evaluation of Institutional Special Needs Plans.  Am J Manag Care. 2019;25(9):438-443.PubMedGoogle Scholar
4.Baggett  TP, Berkowitz  SA, Fung  V, Gaeta  JM.  Prevalence of housing problems among community health center patients.  JAMA. 2018;319(7):717-719.
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5.Hirschtritt  ME, Binder  RL.  Interrupting the mental illness-incarceration-recidivism cycle.  JAMA. 2017;317(7):695-696. doi:10.1001/jama.2016.20992
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6.Koh  HK, O’Connell  JJ.  Improving health care for homeless people.  JAMA. 2016;316(24):2586-2587.
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7.Dettling  M, Anghelescu  I.  Housing for homeless adults with mental illness.  JAMA. 2015;313(24):2493.
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8.Thomas  KS, Durfey  SNM, Gadbois  EA,  et al.  Perspectives of Medicare Advantage Plan representatives on addressing social determinants of health in response to the CHRONIC Care Act.  JAMA Netw Open. 2019;2(7):e196923.PubMedGoogle Scholar
9.Givas  N. Exclusive: Trump shares plans to combat homelessness and mental illness in interview with Tucker Carlson. Fox News website. https://www.foxnews.com/politics/trump-tucker-exclusive-interview-homelessness.Published July 1, 2019. Accessed December 23, 2019.
10.Bamberger  J.  Reducing homelessness by embracing housing as a Medicaid benefit.  JAMA Intern Med. 2016;176(8):1051-1052.

February 24, 2020 Response to Viewpoint: Homeless Special Needs Plans for People Experiencing Homelessness, Feb. 13

Valerie Swenson, MA and BA, CPC; MN Rep. Mindy Greiling | Health Care for All Minnesota


In response to Sachin H. Jain's Feb. 13th Viewpoint, it is important to note that Jain is employed by a Medicare Advantage HMO. Medicare Advantage plans are highly profitable insurance plans. They are privatized versions of our traditional Medicare program. They gain a marketing “advantage” by including the word “Medicare” in their name. They profit off of what was originally meant to efficiently serve all of us - our publicly funded Medicare program. The U.S. General Accountability Office report 16-76 found that traditional Medicare had to send $14 billion in unwarranted payments in a single year to the Advantage plans because of their ability to game the system.

Jain apparently is proposing that Congress address the homelessness problem by funneling even more tax dollars through insurance companies that participate in Medicare Advantage. He appears to be capitalizing on the current wave of real interest in finally addressing our country’s dire lack of affordable housing. Jain is proposing that health care providers treat “homelessness” by using a diagnostic indicator that would support billing an ambiguous capitation cost, a cookie cutter price, for all providers, and then Medicare dollars would be sent to private Medicare “Advantage” companies for their financial gain. Paying health insurance companies to house the homeless is a bad idea.

Health care providers treat illnesses and injuries. Doctors and nurses struggle to find time to attend to their patients and also consistently comply with complex documentation guidelines that support accurate coding and billing processes. To suggest that providers also treat homelessness and bill for it, so that Medicare Advantage companies can profit, sounds like nothing short of outlandish greedy profiteering.

Let’s not pretend that doctors and nurses have the time to tackle homelessness. Paying Medicare Advantage plans to house the homeless is an extremely costly and inefficient way to provide shelter to the homeless.

Sincerely,

Mindy Greiling and Valerie Swenson

Former MN Rep. Mindy Greiling and Medical Coder, Valerie Swenson, CPC, both serve on the leadership team of the Roseville Area Advocates for Minnesota Health Plan(RAAMHP,) a chapter of Health Care for All Minnesota(HCAMN.)

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