AHCCCS	Janice  K. Brewer, Governor

Arizona Health Core Cost Containment System

September 17, 2014 Scott Cummings
Care 1st
2355 East Camelback Suite 300
Phoenix, Arizona 85016

RE: Performance for Acute-Care Clinical Quality Measures Dear Mr. Cummings:

Thomas J. Betlach, Director

The Arizona Health Care Cost Containment System (AHCCCS) has completed the review and evaluation of Contractor results of the contractual Clinical Quality Performance Measures for Contract Year End (CYE) 2012. Performance measure rates were evaluated  in  two  ways: whether they met the Minimum Performance Standard (MPS) outlined in Contract and whether there was a statistically significant decline in the rate from the previous measurement period. Based upon the results of the review, Contractors are subject to regulatory action including over
$1.4 million in financial sanctions.

AHCCCS places significant emphasis on the selected Performance Measures in contract as it is believed that those measures have the greatest ability to positively impact member health outcomes. For the CYE 2012 Measurement Period<l), a specific subset of Contract Performance Measures were selected for evaluation and reporting as AHCCCS was beginning the transition process to the new measure vendor and wanted to ensure appropriate allocation of resources to support both  efforts. With such in mind, the CYE 2012 measurement period results that are included in Attachment A are those measures that AHCCCS officially evaluated. Regulatory action on the KidsCare performance measures is not being taken for the CYE 2012 measurement period; however, data related to KidsCare performance  is provided for your review in Appendix B.

In August 2012, AHCCCS notified Contractors of Notices to Cure based on continued non­ compliance with Minimum Performance Standards (MPS) outlined in contract.  Over  $2.75 million in financial sanctions were initially assessed although some were waived so that resources could be redirected to the measures; additionally, Contractors were required to participate in quarterly technical assistance sessions with AHCCCS staff. While mandated technical assistance is not being required as part of this evaluation, Contractors are encouraged to reach out to AHCCCS staff for assistance if barriers exist that prevent improving and/or sustaining performance measure rates.

Notice to Cure

AHCCCS has evaluated each Contractor's final results  of the Contract Performance  Measures for the CYE 2012 measurement period and compared them with the CYE 2011 measurement period and the Minimum Performance  Standards (MPS) in the CYE 2012 Contract.   Measures

701 East Jefferson, Phoenix, AZ 85034 • PO Box 25520, Phoenix, AZ 85002 • 602-417-4000  • www.azahcccs.gov

that are below the MPS have been issued a Notice to Cure. This action will be reflected in subsequent measurement period evaluations as part of the  regulatory  action  consideration process and could lead to additional Contractor reporting requirements if deemed necessary.

Sanctions

Measure rates that do not meet the MPS and measure rates that show a statistically significant decline are subject to sanctions for this measurement period. Each rate that did not meet the MPS was assessed a full sanction. Each rate that showed a statistically  significant decline but remained above the MPS was assessed a sanction at 50 percent of the full sanction amount.

AHCCCS is sanctioning the Contractor a total of $150,000 for the following  measures,  as allowed in Contract:

Adolescent Well Care	$50,000	
EPSDT  Participation	$50,000	
EPSDT Dental Participation	$50,000	

This sanction will be withheld from an upcoming capitation payment.

Corrective Action Plans

Per Attachment  A, the Contractor will note the measures that should have a Corrective Action Plan (CAP). However, due to the timing of this Notice, the CAPs are being waived. Please note that Contractors should have internal processes in place to ensure ongoing evaluation of measures as well as implementation of effective interventions if measures are at risk of  not meeting the MPS or having a statistically significant decline. CAPs will be required for the CYE 2013 Measurement Period, as appropriate.

Future Performance

It is expected that all Performance Measures meet or exceed the Minimum Performance Standards outlined in the  Contract. Additionally, it is expected that  measures do not show a statistically significant decline from year to year. At least annually, AHCCCS may take additional regulatory action if the Minimum Performance Standards are not met  and/or statistically significant improvement is not shown.  Regulatory actions may include continuation of actions listed above, including additional sanctions, as allowed in the Contract.

Per the terms of your contract, sanctions are not AHCCCS' exclusive remedy. In particular and without limiting possible  future actions, if any legal action is brought  against AHCCCS as the result of Contractor non-compliance with the Contract, AHCCCS will seek compensation from the Contractor for any damages arising from such legal action, including but not limited to AHCCCS' cost of representation, as well as the cost of any attorney's fees and costs payable to the party bringing the action.

If you disagree with this sanction, you may file a dispute with AHCCCS using the  process outlined in A.A.C. R9-34-401, et seq. The dispute must be filed in writing and must be received by AHCCCS no later than 60 days from the date of this letter. The dispute shall specify the legal and factual bases for the dispute, as well as the relief requested.  Dispute letters should be sent to:

AHCCCS
Office of Administrative Legal Services 701 E. Jefferson
Phoenix, AZ  85034

If you have any questions regarding this letter, please contact Kim Elliott at 602-417-4782 or Kim.Elliott@azahcccs.gov.

Michael Veit,
Contracts and Purchasing Administrator

cc:        Patty Dal Soglio, Contract Compliance Officer, Care 1st
Kim Elliott, PhD, CPHQ, Clinical Quality Administrator, DHCM, AHCCCS Kari Price, Assistant Director, DHCM, AHCCCS
Shelli Silver, Assistant Director, DHCM, AHCCCS

Attachment A:  Care 1st Performance Measure Re·

CVE 2011
Performanc e  (10/01/10-	
CVE 2012		Significance		Minimum Performance	Relative		Performanc
Level
{10/01/11-	Percent Change	e Standard
(p value)	
	09/30/12}	

97.2%	
97.8%	
0.7%	
0.245	
93%	

87.5%	
87.5%	
0.0%	
0.993	
83%	

87.8%	
89.4%	
1.8%	
0.030	
83%	

84.4%	
85.8%	
1.6%	
0.104	
81%	

78.4%	
80.4%	
2.5%	
0.212	
65%	

65.3%	
66.9%	
2.4%	
0.056	
66%	

33.1%	
34.9%	
5.6%	
0.056	
42%	

62.2%	
62.9%	
1.1%	
0.155	
57%	

67.4%	
65.7%	
-2.5%	
<0.001	
68%	

43.4%	
43.6%	0.4%	0.59	46%	

Performance Measure

Children's Access to Care (12-24 mo.)

nual Dental Visits

EPSDT Participation

EPSDT Dental Participation

view

	
Current
Statewide Average	
Sanction
(Y/N)	Notice to Cure (Y/N)	CAP
Required
(Y/N)	

97.0%	
N	
N	
N	

87.7%	
N	
N	
N	

89.9%	
N	
N	
N	

87.7%	
N	
N	
N	

67.8%	
N	
N	
N	

66.8%	
N	
N	
N	

38.0%	y	y	y	

61.8%	
N	
N	
N	

65.7%	
y	
y	
y	

44.1%	
y	
y	
y	

Attachment  B:  Care 1st Performance Measure Review

CVE 2011	CVE 2012	Significance	Minimum

Performance Measure

Performanc	Performance	Relative
e {10/01/10-	{10/01/11-	Percent Change
09/30/12)

Level
(p value)

Performanc e Standard

n/a	n/a	93%

94.2%	95.0%	0.9%	1	83%

95.8%	95.9%	0.1%	1	83%

91.3%	93.6%	2.6%	0.412	81%

0.0%	n/a	n/a	65%

70.5%	85.0%	20.5%	0.077	66%

Visits

45.9%	52.5%	12.6%	0.208	42%

Annual Dental Visits	79.9%	75.1%	-6.5%	0.108	57%

Current Statewide Average	

100.0%	

93.9%	

95.9%	

94.0%	

0.0%	

76.6%	

55.1%	

77.8%