Primary care sub-capitation program
As of April 1, 2023, all primary care providers (PCPs) participating in MassHealth’s ACO program will be paid through the Primary Care Sub-Capitation Program. The Primary Care Sub-Capitation Program is a required component of the MassHealth program during the new waiver that begins on April 1.
Definitions
Included codes: Codes that are eligible for zero payment as defined by MassHealth. A list of included codes can be found in the “References” section of this document.
PC sub-cap: Program defined and administered by MassHealth.
PID/SL: Provider ID / Site Location of a PCP group as determined by WellSense and our ACO partners and communicated to MassHealth.
Primary Care Entity: MassHealth defines a PCE as a Tax ID Number (TIN) that has one or more sub-cap eligible PID/SLs associated with it in MassHealth’s system.
Sub-cap eligible PID/SL: A PID/SL submitted by WellSense ACOs on revised Attachment C that appears on the monthly ACO-4 report and is assigned a monthly rate by MassHealth.
Calculation of monthly payments
WellSense will calculate monthly payments for each primary care entity (PCE) based on MassHealth guidance. Each PCE will correspond to a single TIN. WellSense will calculate the number of members in each rating category attributed to the TIN as of the first of the month. This calculation will be done at the level of each PID/SL that is associated with the TIN. WellSense will then multiply the number of member-months in each rating category by the MassHealth-assigned PC sub-cap rate for each rating category. The sum-total of this calculation will be the payment remitted to the TIN.
MassHealth has identified a small number of groups as using “facility only TINs” to split bill their primary care services. Beginning in January 2024, these facilities will receive monthly sub-cap payments based on the membership attributed to their corresponding professional TIN(s). Affected groups will receive a separate communication with details of the process.
Fractional member-months
If a member is only eligible for part of a month, WellSense will pay using fractional member-months for the portion of the month in which the member was eligible.
If a member is attributed to one PCE during the beginning of the month but switches partway through, WellSense will use the PCE the member belonged to on the 1st of the month for the entire month. In other words, WellSense will not “split” a member-month across more than one PCE.
PID/SL discrepancies
In some cases, due to provider movement, a particular PCP at a given primary address may not match to the list of PID/SLs from the MassHealth ACO-4 report that were assigned PC sub-cap rates. In these cases, WellSense will use internal logic to attribute the PCP to an appropriate PID/SL affiliated with the same TIN. If the PCP is set up under a TIN that does not have a sub-cap eligible PID/SL affiliated with it, WellSense will not be able to pay that PCP the monthly cap. WellSense will reach out to the provider group in question to attempt to resolve the issue.
Payment of monthly payment
WellSense will process the payment on the second Monday of each month. The payments will be remitted to the provider groups using the same payment method utilized when processing other weekly payments (via check or ACH). TINs receiving funds via check are encouraged to switch to ACH payments in order to improve the efficiency and security of payments. Providers may change their payment method by contacting WellSense’s Provider Relations Department at provider.Info2@wellsense.org.
Payments will be sent with a remittance code that will indicate that the payment is the monthly sub-cap payment.
Administration of claims
WellSense will implement claims processing logic to suppress claims that aligns with the guidance laid out by MassHealth.
- WellSense will check the member’s eligibility to determine if the member was eligible on the date of service. If the member was not eligible, the claim will be denied. Otherwise, the logic will proceed to Step 2.
- WellSense will compare the TIN of the member’s PCP group to the TIN of the Servicing/Rendering provider submitted on the claim. If the TINs do not match, the claim will pay fee-for-service according to usual claims payment rules. Otherwise, the logic will proceed to Step 3.
- MassHealth has identified a small number of groups as using “facility only TINs” to split bill their primary care services. For dates of service on or after 01/01/2024, claims billed for attributed members under the facility-only TIN will also be $0 paid under the sub-cap if they meet the criteria in Steps 3 and 4. Affected groups will receive a separate communication with details of the process.
- WellSense will determine the provider type of the servicing provider on the claim in question. If the provider type is physician, GPO, FQHC, hospital-licensed health center (HLHC) or general acute care hospital, the logic will proceed to Step 4. Otherwise, the claim will pay fee-for-service according to usual claims payment rules.
- Urgent care claims, defined as claims billed with Place of Service 20, Revenue Code 0516 or Revenue Code 0526, will be paid fee-for-service
- Step 4 will depend on the type of claim and provider.
- If the claim is from a non-hospital licensed FQHC, the logic will proceed immediately to Step 5.
- If the claim is a HCFA claim from an HLHC or non-FQHC, WellSense will look at the servicing provider’s specialties in their Facets record to determine if the claim is considered “primary care.” If the provider has at least one included specialty and no excluded specialties from the MassHealth Specialty List (found in the references section of this document), the logic will proceed to Step 5. Otherwise, the claim will pay fee-for-service according to usual claims payment rules.
- If the claim is a UB claim from a HLHC or non-FQHC, WellSense will look at the attending provider’s specialties in their Facets record to determine if the claim is considered “primary care.” If the provider has at least one included specialty and no excluded specialties from the Specialty List (found in the references section of this document), the logic will proceed to Step 5. Otherwise, the claim will pay fee-for-service according to usual claims payment rules.
- If the attending provider is not found in WellSense’s system, WellSense will pay the claim fee-for-service according to usual claims payment rules.
- WellSense will then look at the list of codes on the claim to determine if any are on the MassHealth Included Code list (found in the references section of this document). Any code on the list of included codes will be paid $0. Codes not on the included list will be paid fee-for-service according to usual claims payment rules.
Retroactivity
WellSense will process retroactive changes within a three-month lookback period. If a member’s rating category, eligibility or PCP assignment (outside of the same TIN) changes within the lookback period, WellSense will re-process the monthly payments to either increase or decrease the payment.
WellSense will not “split” months between PCPs, so retroactivity will only apply for PCPs if the member is retroactively attributed to a new PCP as of the 1st of the month.
Escalations
If a provider group has questions about their per-member per-month payments, they should direct those questions to their assigned Provider Relations Consultant, who will then route the question to the appropriate internal team.
If a provider group has questions about a zero paid claim, they should contact Provider Services or their Provider Relations Consultant. They will then route the question to the appropriate team for investigation.
Monthly roster reviews
On a monthly basis, WellSense will share with all PCP groups participating in the sub-cap program a roster of their current PCPs, including primary address. The PCP groups are responsible for updating this information in a timely fashion so that information in WellSense’s systems remains accurate.
If a provider has not completed their monthly roster review, WellSense will not make retroactive adjustments for discrepancies that are due to out-of-date address or other data.
References
Review the included code and specialty lists to view the eligibility of zero payments as defined by MassHealth.
Sub-Capitation Program FAQ
MassHealth specialty logic
We employ a nurse practitioner or physician assistant who works in a specialty clinic, but they bill using the same TIN as some of our PCPs. Does this mean some of their claims will be zero paid?
Yes, according to the MassHealth logic, those providers’ claims for included codes will be zero paid if they are seeing a member who is attributed to a PCP who bills under the same TIN.
What happens if we have a cardiologist who is dually boarded in internal medicine? Does that mean all of their claims will be zero paid under the cap?
This provider’s claims for included codes would be zero paid if they are seeing members who are attributed to a PCP who bills under the same TIN. If the provider bills under a different TIN, then their claims will be paid fee for service.
My clinic employs a provider who is dually boarded in family medicine and psychiatry and carries a panel. Will their claims be zero paid under the cap?
Usually no. This provider’s claims will usually be paid fee for service because they are excluded under the MassHealth specialty logic criteria. The exception is if your clinic is a non-hospital-licensed FQHC, in which case all claims for your attributed members will be zero paid regardless of provider specialty.
My clinic employs an endocrinologist who is only boarded in endocrinology, not internal medicine, but serves as a PCP for certain patients. Will their claims be zero paid under the cap?
Usually no. This provider’s claims will usually be paid fee for service because they are excluded under MassHealth specialty logic criteria. The exception is if your clinic is a non-hospital-licensed FQHC, in which case all claims for your attributed members will be zero paid regardless of provider specialty.
We are a federally qualified health center (FQHC) that employs specialists. What will happen to their claims?
The answer depends on whether your FQHC is hospital licensed or not. If your FQHIC is hospital licensed, claims will zero pay (or not) according to MassHealth’s standard specialty logic, which takes into account the specialties of the providers rendering the service.
If your FQHC is not hospital licensed, all of your claims for included codes will zero pay for members attributed to your health center regardless of the provider’s specialty.
Billing and coding
I am a PCP who is going to bill a code that is not on the MassHealth included code list, but is also not on the excluded list. Will this code zero pay?
No. WellSense will only zero pay codes that appear on the MassHealth included code list.
My clinic drops both facility and professional claims for primary care visits. Would both claim types be zero paid under this program?
The answer depends on the TIN used for billing each claim. If your group uses the same TIN for both facility and professional claims, then both will be zero paid under the sub-cap program if the member is attributed to that TIN. If your group uses a separate TIN for facility claims, they will be excluded from sub-cap and paid fee-for-service during the first year of the program.
How do I know if a claim zero paid because of PC sub-cap?
The code will have an explanation code of “CAP” on paper remits or CARC 24 (“Charges are covered under a capitation agreement/managed care plan”) on electronic remits.
PID/SLs and provider attribution
My group has several locations, and each location has several PCPs. If a member is assigned to location A but goes to location B, will their claims be zero paid?
The answer depends on the TIN each location uses for billing. If the providers at both locations use the same TIN, then the claims will be zero paid. If the providers at each location use different TINs, then the claims will be paid fee for service.
What happens if my clinic sees a patient for primary care who is not attributed to our group?
If that patient is a member of your same ACO but is not attributed to a group that bills under the same TIN as your group, the claim will pay fee-for-service.
Monthly payments
How does WellSense calculate monthly cap payments?
WellSense follows MassHealth guidance for calculating monthly cap payments. To do so, we multiply the number of members attributed to a TIN on the first day of each month in each rating category by the rate that MassHealth calculated for your group’s TIN + rating category combination. If a member was eligible for only part of a month, they will receive a prorated payment based on the percentage of the month they were eligible.
Does WellSense use the MassHealth specialty logic to determine which PCPs get monthly cap payments?
No, WellSense only uses the MassHealth specialty logic to determine which claims to zero pay. WellSense looks at which providers have members attributed to them in our system in order to calculate monthly cap payments. A provider will only have members attributed to them if your group has indicated to us that the provider is a PCP with an open panel on your provider enrollment forms. You can always update provider information with us by using our Provider Change and Termination form.
What happens if one of my providers practices at more than one group? Can they get more than one payment?
WellSense creates a unique provider record for each national provider identifier (NPI) and TIN combination. This means that if the provider practices at two different locations that bill under two different TINs, the provider can carry separate panels. However, if the two locations use the same TIN for billing, the provider can only carry a panel at one of those locations. In this case, if the provider sees a member attributed to their primary location at another location, that claim would still be zero paid.
For the purposes of PC cap, we are attributing the provider to the address that your group has indicated is their primary practice location. If you would like to update their primary location, you can submit a Provider Change and Termination form at any time.
Will we get more tier dollars if we assign new members to one of our locations with a higher tier?
Not at first. MassHealth has integrated tier payments into the rates they have set for each TIN. They have reserved the right to recalculate those tier payment midyear, but at least for the first few months of the program, the distribution of your members across your tiers will not affect your per-member rates.
What happens to my monthly payments if a member becomes retroactively eligible (or ineligible) for MassHealth?
WellSense will use a three-month lookback period to adjust monthly payments for retroactivity. This means that if a member becomes retroactively eligible, you will see a positive adjustment in your next month’s payment. If they are retroactively ineligible, you will see a negative adjustment.
What happens to my monthly payment if a member joins MassHealth mid-month and gets attributed to my group?
WellSense is using a three-month lookback period for adjustments. At the beginning of the month following the member’s arrival or departure, our system will automatically include the new member. At that time, WellSense will calculate the appropriate fractional payment for the prior month and account for this as a positive adjustment. The same logic will apply if a member is disenrolled midmonth. You will see a negative adjustment in the next month’s payment.
What happens if an existing MassHealth member switches PCPs and joins my group mid-month?
You will receive the full monthly payment for the member starting the next month. WellSense uses the member’s attribution as of the first day of the month to allocate the full month’s payment. WellSense is not calculating fractional payments if a member switches groups mid-month.
I have a question about my monthly cap payment. Whom should I contact?
Please contact your assigned Provider Relations Consultant with questions related to PC sub-cap monthly cap payments.
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