Dive Brief:
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The HHS’ Office of Inspector General released Monday an advisory opinion regarding a pharmaceutical manufacturer’s proposal to collaborate with a trade association, a Medicare Advantage (MA) plan and a hospital system on a pilot program.
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The program would implement, fund and evaluate a pilot program that would include MA plan pharmacists conducting medication therapy management (MTM) services with new technology allowing for real-time electronic access to patient discharge information, wrote Robert DeConti, HHS OIG assistant inspector general for legal affairs.
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The OIG said the arrangement, which is not named in the advisory opinion, would not violate anti-kickback statutes and the office wouldn't impose administrative sanctions against the described program.
Dive Insight:
The OIG said the pilot program would see how technology can improve transitions of care and decrease re-hospitalizations. Specifically, the program would involve MA members admitted to the hospital with one of the five diagnoses eligible under the Hospital Readmission Reduction Program: pneumonia, congestive heart failure, acute myocardial infarction, chronic obstructive pulmonary disease and elective total hip or knee arthroplasty.
In its advisory opinion, OIG said the project as described should pass muster. The pharmaceutical manufacturer’s involvement would provide new technology for MTM pharmacists, but there would be safeguards in place to prevent influencing prescribing or formulary decisions. Plus, the program would not give new technology to the hospital, the program would likely not increase costs, the arrangement would not interfere with MTM pharmacists’ clinical decision-making, the partnership would not likely harm patient care and the program is limited in number of patients (about 200), scope and monetary investment.
“Overall, the Proposed Arrangement as described herein presents minimal risk to patients or federal healthcare programs,” states OIG.
Though the OIG redacted the parties involved, the advisory opinion does allow for more room for payer-provider integration in MA as long as it fits current regulations. Payers and providers have increasingly worked together on value-based programs, but the MA program mentioned goes well beyond that and includes additional healthcare stakeholders.
Looking ahead to additional partnerships, Thomas Robinson, partner at Oliver Wyman, recently told Healthcare Dive, “Successful partnerships will take the opportunity to innovate around the product and experience now that the incentives, insight, investment and integration are all for it.”
Another interesting aspect of this program is that it involves the MA patient population. Payers have increasingly moved into MA and view the market more positively than the Affordable Care Act exchanges. Payers like the stability in the market and the constant flow into the market of new healthier customers that become eligible for Medicare daily. The OIG advisory opinion shows that not only payers are interested in the MA market, but other healthcare stakeholders, too.