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HB22-1325 - Primary Care Alternative Payment Models

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On May 18, 2022, Governor Polis signed House Bill 22-1325 (HB 22-1325) into law, which directed the DOI to establish aligned parameters for primary care alternative payment models (APMs) to improve health care quality and outcomes in a manner that reduces health disparities and actively advances health equity, and increases the number of Coloradans who receive the right care in the right place at the right time at an affordable cost. Over the course of 2023, the DOI engaged a broad array of stakeholders - including the Department of Health Care Policy and Financing, the Department of Personnel, the Department of Public Health and Environment, the Primary Care Payment Reform Collaborative (PCPRC), and health insurance carriers and providers participating in APMs - in a series of discussions to develop aligned parameters for APMs for primary care services in health benefit plans.  

The DOI adopted Colorado Insurance Regulation 4-2-96 on by December 1, 2023, establishing alignment requirements related to four APM design components: quality measures, patient attribution, risk adjustment, and core competencies. Additional information regarding these requirements, as well as activities related to the ongoing implementation of HB 22-1325, will be available on this website.

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*     *     *     DRAFT Primary Care and APM Reporting Guidance     *     *     *

The DOI has released DRAFT Proposed Amended Regulation 4-2-72, Concerning Strategies to Enhance Health Insurance Affordability, which has been updated to include all reporting requirements related to primary care investment and APM alignment. The DOI is seeking comments on a DRAFT Primary Care and APM Reporting Template, developed in conjunction with DRAFT Proposed Amended Regulation 4-2-72. 

DRAFT Proposed Amended Regulation 4-2-72 Concerning Strategies to Enhance Health Insurance Affordability 

DRAFT Primary Care and Alternative Payment Model (APM) Reporting Template 

Please submit your comments on this draft proposed regulation and/or the draft reporting template no later than 5 PM, May 10th, 2024 to DORA_INS_RulesandRecords@state.co.us.

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For questions about the Division's primary care and APM work, and/or if you would like be added to the stakeholder email distribution list for HB 22-1325 implementation, please send your name and contact information to Tara Smith, the Division's Primary Care and Affordability Director (tara.smith@state.co.us).

Quality Measure Stakeholder Engagement Group

The aligned APM parameters for primary care must include, per the requirements of HB22-1325(opens in new window)(opens in new window)(opens in new window)(opens in new window), an aligned quality measure set that considers the quality measures and the types of quality reporting that health insurance carriers and providers are engaging in under current state and federal law. In addition, the aligned quality measure set must include quality measures that are patient-centered and patient-informed and address: pediatric, perinatal, and other critical populations; the prevention, treatment, and management of chronic diseases; and the screening for and treatment of behavioral health conditions.

The Division, with the support of the Health Care Payment and Learning Action Network (HCP LAN), held a series of stakeholder meetings to obtain input on aligned quality measure sets for adult and pediatric populations- meeting materials, and the final quality measure recommendations, can be accessed by clicking on the links below:

Quality Measures - Stakeholder Meeting Materials          Quality Measures - Technical Specifications

Patient Attribution Stakeholder Engagement

The aligned APM parameters for primary care must include, per the requirements of HB22-1325, utilize patient attribution methodologies that are transparent and reattribute patients on a regular basis. Patient attribution methodologies must also ensure that population-based payments are made to a patient's primary care provider rather than other providers who may only offer sporadic primary care services to the patient, and include a process for correcting misattribution that minimizes the administrative burden on providers and patients. 

The Division, with the support of the Health Care Payment and Learning Action Network (HCP LAN), held a series of stakeholder meetings to obtain input on aligned patient attribution methodologies. Stakeholders were also invited to provide feedback through a brief survey related to patient attribution. Meeting materials, and a copy of the survey form, can be accessed by clicking on the links below: 

Patient Attribution Stakeholder Meeting Materials          Patient Attribution Survey

Risk Adjustment Stakeholder Engagement

The aligned APM parameters for primary care must include, per the requirements of HB22-1325, include transparent risk adjustment parameters that ensure that primary care providers are not penalized for or disincentivized from accepting vulnerable, high-risk patients. Risk adjustment parameters must also ensure primary care providers are rewarded for caring for patients with more severe or complex health conditions, and patients who have inadequate access to affordable housing, healthy food, or other social determinants of health. 

The Division, with the support of the Health Care Payment and Learning Action Network (HCP LAN), held a series of stakeholder meetings to obtain input on aligned risk adjustment methodologies - meeting materials can be accessed by clicking on the link below:

Risk Adjustment - Stakeholder Meeting Materials

Core Competencies Stakeholder Engagement

The aligned APM parameters for primary care must include, per the requirements of HB22-1325, include a set of core competencies around whole-person care delivery that primary care providers should incorporate in practice transformation efforts to take full advantage of various types of alternative payment models.

The Division, with the support of the Health Care Payment and Learning Action Network (HCP LAN), held a series of stakeholder meetings to obtain input on aligned core competencies for whole-person care delivery. Stakeholders were also invited to provide feedback through a brief survey related to patient attribution.  Meeting materials, and a copy of the survey form, can be accessed by clicking on the links below:

Core Competencies Stakeholder Meeting Materials                  Core Competencies - Survey