OHA releases draft RFA for CCO 2.0
On Friday, the Oregon Health Authority (OHA) released its draft request for applications (RFA) for the new CCO 2.0 contracts. The draft RFA is available for public comment until January 14, and the final RFA will be released January 25, 2019.
The draft RFA includes the principal document, along with 16 attachments that prioritize the Oregon Health Policy Board’s adopted policy recommendations:
- Increase value and pay for performance
- Focus on social determinants of health and health equity
- Improve the behavioral health systems and address barriers to access to and integration of care
- Maintain sustainable cost growth and ensure financial transparency
Questions and requirements for value-based payments are outlined in attachment 8. By the start of the new CCO contract, January 2020, CCOs must begin “with at least 20% of their projected annual payments to their providers in contracts that include a value-based payment component.” In addition, CCOs will be required to develop new or expanded VBPs in care delivery areas that include maternity care, behavioral health care, children’s care, oral health, and hospital care.
After 2020, CCOs will need to continually implement new VBPs and increase the level of payments that are value-based with the goal of no less than 70 percent VBP by 2024.
Social Determinants of Health and Health Equity (SDOH-HE):
Attachment 10 of the draft RFA addresses social determinants and health equity. As part of their application process, applicants will need to engage key stakeholders such as community organizations that address social determinants and disparities as well as Tribes and public health authorities.
The RFA also outlines key investments that CCOs will need to make. Starting in 2020, CCOs will be required to use a portion of their end-of-year surplus on health disparities. For the first two years of SDOH-HE spending, there will be a statewide focus on investment in housing-related services and supports – and OHA may develop new state priorities in subsequent years.
OHA also plans to create an incentive arrangement by offering bonus payments above capitation rate to CCOs that meet certain SDOH-HE performance milestones. These milestones and details of the Bonus Fund should be issued to CCOs in the fall of 2020.
Behavioral Health & Care Integration:
As an overarching requirement, all applicants “must be fully accountable for the Behavioral Health benefit to ensure Members have access to an adequate provider network, receive timely access to the full continuum of care, and access effective treatment.” To ensure this accountability, the RFA includes several detailed questions for applicants related to care integration, mental health parity, contracting, and access.
As part of their covered services, applicants will need to address substance use disorder, prioritize access for women and children, ensure care coordination for individuals with severe and persistent mental illness, and guarantee Wraparound Services are available for eligible children and young adults. CCOs will also be required to enter a MOU with Local Mental Health Authority to improve behavioral health outcomes and improve access to care.
Costs & Financial Transparency:
Questions and requirements related to costs and finances are available in Attachment 12. Beginning in 2022, profit load in CCO capitation rates will vary based on CCO performance – with the goal of incentivizing CCOs to improve the delivery of benefits. These improvements could include using medical services more efficiently or increasing the use of appropriate health-related services.
The RFA includes a section dedicated to increasing the transparency between CCOs and Pharmacy Benefit Managers (PBMs) and requires “no-spread contracts” between the two entities.
OHA are also requiring CCOs to engage in enhanced financial reporting based on the financial standards used by the National Association of Insurance Commissioner, achieve sustainable growth targets, and have the capacity to perform regular provider audits and claims review.
The new Coordinated Care Organization contracts will run from 2020-2024.