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As part of the strategy of the Texas Health and Human Services Commission (“HHSC”) to preserve the existing Uncompensated Care (UC) pool size in future fiscal years and to advance quality goals and strategies under the federal regulations, HHSC has indicated that it plans to establish the “Medicaid Managed Care Aligning Technology by Linking Interoperable Systems for Member Health Outcomes Program” (“ATLIS”) under the authority of 42 C.F.R. 438.6(b)(2). Under this program, certain STAR, STAR Plus, and STAR Kids managed care organizations will be eligible for incentive payments of up to 5% above their capitation for achieving with respect to HHSC-designated performance metrics. The ATLIS Program is scheduled to go live on September 1, 2024.
As a 438.6(b)(2) program, any downstream payments to providers derived from managed care incentive payments will not be mandated or directed by the state. Even though HHSC intends to focus on hospital-related achievement benchmarks intended to encourage cooperation and financial arrangements between managed care organizations and hospitals, consistent with federal requirements, HHSC has made clear that it will not regulate any arrangements between managed care organizations and hospitals regarding any payments to hospitals associated with managed care incentive payments.
While HHSC has indicated it will not participate in structuring any managed care organization-provider payment arrangements resulting from ATLIS, HHSC's financial modeling for the program to date clearly indicates HHSC's expectation that managed care organizations will enter into payment arrangements to share a substantial portion of any managed care incentive payments with its participating hospitals. The modeling also indicates HHSC's expectation that incentive payment amounts shared with a managed care organization's participating hospitals will be further allocated among such hospitals according to HHSC-derived methodologies that take into account respective utilization numbers, hospital classes, and SDAs.
UNIT is creating one or more networks of hospitals that will be utilized in contracting with MCOs with respect to ATLIS activities. At minimum, UNIT is positioned to serve as a go-between/facilitator with respect to ATLIS between a contracted managed care organization and UNIT's contracted hospitals (“Network Hospitals”) that are also participating hospitals of the managed care organization. UNIT is also willing and able to contract to render comprehensive program management services to the managed care organization with respect to ATLIS, resulting in UNIT serving as the go-between/facilitator with respect to ATLIS between the managed care organization and all of the managed care organization's participating hospitals, even those that are not Network Hospitals.
Under the aforementioned roles, UNIT's primary intent will be to best ensure that any managed care incentive payment proceeds received by a managed care organization contracted with UNIT will be shared downstream with the managed care organization's applicable participating hospitals in a manner consistent with the allocation methodology principles set forth in HHSC's program financial modeling and HHSC's communicated program policy initiatives.
We are happy to schedule a call to discuss how UNIT may be of assistance in executing the ATLIS Program for any Provider or Managed Care Organizations. For more information on the ATLIS program or UNIT Network, please contact Adam Aseron, adam@unittexas.com, and Briana Homerstad, bhomerstad@unittexas.com, via email.
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Austin, Texas 78701
