IAH Demonstration FAQs
The following frequently asked questions were originally published on the Center for Medicare & Medicaid Innovation website.
Background and Eligibility Information
Practices must meet the following requirements in order to be eligible for the Demonstration.
The practice must be a legal entity comprised of physicians or nurse practitioners, or a group of physicians or nurse practitioners, that provide care as part of a team that may include physician assistants, clinical staff, and other health and social service staff who:
Have experience providing home-based primary care to applicable beneficiaries;
Make in-home primary care visits;
Are available 24 hours a day, 7 days a week to carry out plans of care tailored to an individual patient’s needs;
Organized at least in part for the purpose of providing physician services;
Uses electronic health records, remote monitoring, and mobile diagnostic technology;
Furnishes services to an average of 200 or more applicable beneficiaries during each year of the Demonstration;
Reports information about their patients and the health care services provided; and
Reports on required quality measures.
Option 1: Any practice meeting the eligibility criteria may apply as a sole legal entity.
Option 2: Multiple primary care practices within a geographic area may form a consortium in order to participate. Any practice that decides to participate in a consortium in a geographic area must provide the Taxpayer Identification Numbers(TINs) of all the applying practices and must designate a single TIN that will act as the agent for the consortium and be responsible for distributing any incentive payments to all the individual practices that comprise the consortium.
All the practices participating in the consortium will be treated by CMS as one IAH practice for the purpose of establishing expenditure targets, evaluating quality, and determining incentive payments.
Option 3: Practices with a beneficiary caseload ranging from 200 to 500 beneficiaries may choose to become a part of a national pool of providers. Providers participating in a national pool will waive the right to have savings evaluated as a single practice and all financial targets will be calculated based on the pooled practices. Savings will then be distributed according to (1) practice-level, risk- and frailty-adjusted beneficiary months of enrollment and (2) number of quality measures met at the practice level (see questions E.4. and E.5).
once a practice elects to participate in a selected option, the practice will remain in that option for the entirety of the Demonstration.
Be entitled to Medicare benefits under Part A and be enrolled in benefits under Part B;
Not be enrolled in a Medicare Advantage (MA) plan under Part C;
Not be enrolled in a Program for All-Inclusive Care for the Elderly (PACE) program under SSA Title 18 Sec 1894;
Have two or more chronic conditions;
Have had a hospital admission within the past 12 months;
Have received acute or sub-acute rehabilitation services within the past 12 months (including skilled nursing facility, home health, and inpatient and outpatient rehabilitationservices); and
Require assistance of another person (assistance may include supervision, cueing, or hands-on help) for two or more activities of daily living (ADL).
Upon discharge from the hospital, CMS expects the practice to provide an in-home visit within 48 hours, to assess the current condition of the beneficiary, and to begin follow-up care.
Upon discharge from the emergency department, CMS expects the practice to provide either an in-home visit to the beneficiary or telephone call to the beneficiary or the beneficiary’s primary caregiver. Phone call follow-ups are acceptable as determined by the IAH physician or nurse practitioner. However, phone call follow-ups are not acceptable for medication reconciliation.
These steps are standard for home-based primary care practices, according to input from clinical experts consulted by CMS.
Independence at Home Demonstration
Centers for Medicare & Medicaid Services
7500 Security Blvd
Baltimore, MD 21244
initial application deadline.
Each consortium should send a single Letter of Intent that includes the following:
A statement that the consortium as a whole furnishes services to at least 200 eligible beneficiaries;
A statement that each of the involved practices meets eligibility requirements;
An approximate number of eligible beneficiaries from each individual practice in the consortium, as well as a total number for the entire consortium;
An address of each individual practice;
The name and address that the consortium will use to form the legal entity (if available); and
The name of the consortium representative who will sign the formal IAH application (if available).
Specific instructions for the Letter of Intent can be found in the Letter of Intent tab of the application.
In the application, briefly describe the system your practice will be using and the plans for incorporating the system into your practice.
Please note that if CMS receives applications that would lead to exceeding 10,000 beneficiaries, CMS may use experience with electronic health information systems as one practice selection criterion.
There are no questions for providers to answer in this tab.
for examples of remote monitoring technology.
After the potential incentive payment is calculated based on the MSR and whether it was achieved at the 5% or 10% level of significance, and at least three of the six quality targets have been achieved, the actual incentive payment to the practice will be based on how many of the quality targets are met. It does not matter which of the quality measures are met.
For practices that select Option 2, and enter the Demonstration as a consortium, CMS will make a single incentive payment to the entity as a whole. It will be up to each consortium to determine how to distribute the payment among its participating practices.
For practices participating under Option 3, the national pool, savings will be determined based on the spending target, actual expenditures, and MSR for all beneficiaries in the national pool. Savings will be distributed to the individual practices according to the individual practice’s risk-adjusted beneficiary months of enrollment and the number of quality measures met by the individual practice.
Beneficiaries may receive Medicare home health services, and any other Medicare-covered service, while receiving their primary medical care through an Independence at Home practice; however, a home health agency does not qualify as a home-based primary care provider unless it provides in-home medical care as a primary medical care provider. Medicare-covered home health benefits are not equivalent to primary medical care provided in the home.
The solicitation states that “practices and their beneficiaries participating in the Demonstration cannot participate in any other program or demonstration that uses shared savings because savings related to a beneficiary with more than one organization cannot be determined without confounding the IAH model of care with the effects of other interventions or models.” There, “practices” refers to the legal entity participating in the Independence at Home Demonstration and does not apply to the larger medical practice.
Section1866E(e)(2) provides that “The Secretary shall not pay an independence at home medical practice under this section that participates in section 1899”; and Section 1899(b)(4)(B) prohibits duplication in participation in shared savings programs by ACO participants and expressly identifies the Independence at Home medical practice pilot as another program that involves shared savings under Medicare.
Therefore, if your practice is already an ACO participant in the Shared Savings Program or you are applying for participation in the Shared Savings Program as an ACO participant, your practice may not also apply to participate in the Independence at Home Demonstration.