THE FLORIDA PHYSICIANS TRUST (FPT) MEDICARE SHARED SAVING PROGRAM (MSSP) ACO QUALITY ASSURANCE PROGRAM

1. Purpose

The Florida Physicians Trust (FPT) Quality Assurance Program represents a comprehensive, integrated, and on-going system designed to objectively and systematically monitor and evaluate the quality and appropriateness of clinical and non-clinical care and services provided to Medicare beneficiaries.

2. Authority

The Board of Directors of FPT has the authority and accountability for the Quality Assurance Program. The Board of Directors has delegated the responsibility for the development, implementation, and on-gong monitoring and evaluation of the Program to the Quality Management and Medical Standards Committee and the FPT Chief Quality Officer.

The Board of Directors is responsible for
1) reviewing and approving the annual evaluation of the Program,
2) reviewing and approving clinical and non-clinical quality improvement studies and projects, and
3) reviewing and approving the strategies and programs for the care and management of with chronic conditions with chronic conditions, and
4) ensuring that sufficient resources are allocated to accomplish the goals and objectives of the Program.

3. Oversight Committee Structure

The delegated functions and responsibilities of the Quality Management and Medical Standards Committee include, but are not limited to:

• Establishing priorities for the FPT Quality Assurance Program.
• Integrating intra-organizational department and functions of the FPT relative to the goals and objectives of the Program.
• Ensuring effective implementation of the Program.
• Ensuring accurate and timely reporting of FPT performance metrics in compliance with the MSSP expectations.
• Analyzing and evaluating trend data from quality assurance special studies and activities and/or department reports and making recommendations to the Board of Directors as necessary.
• Providing a forum within the ACO for discussion of clinical and non-clinical issues related to the quality of care and service provided Medicare beneficiaries.
• Reviewing individual provider and aggregate utilization data, with the development of recommendations for action as necessary.

The standing membership of the FPT Quality Management Steering Committee includes:

• FPT Medical Director as Chairperson

• FPT Chief Quality Officer

• FPT Compliance Officer

• Minimum of three providers (PCPs) from the FPT Participating Provider Network

Additional physicians (network PCPs or specialists) may be invited to attend the FPT Quality Management and Medical Standards Committee meetings on an ad hoc basis to provide input regarding specific clinical and non-clinical quality of care issues.

The Quality Management and Medical Standards Committee meets at least bi-annually with minutes and other informational material made available to the Board of Directors. Copies of all minutes of the Committee must be submitted for review and filing to the FPT Compliance Officer.

4. Participating Provider and Medicare Beneficiary Participation in the Program

Primary care physicians in the FPT Participating Provider Network have the opportunity to participate in the Quality Assurance Program through the following venues:

• Membership on the Quality Management and Medical Standards Committee

• Participation in special studies and/or projects directed at specific clinical and non-clinical issues.

Medicare beneficiaries are afforded an opportunity to participate in the Program through participation in focus groups established by the Committee targeted at specific quality issues or problems, and in special studies and/or projects directed at specific clinical and non-clinical issues. FPT participating providers and aligned Medicare beneficiaries are provided a description of the Quality Assurance Program on the FPT website.

5. Core IT Technology Platform Driving the FPT Quality Assurance Program

The functions and operations of the FPT Quality Assurance Program are facilitated, under contractual agreement, by a proprietary, state-of-the-art, and cloud-based Health Information Exchange (HIE) IT platform operated by Guardian Health Services, LLC. This IT platform, referred to as Guardian, connects providers and enables access to beneficiary-centric clinical information on demand at the point of care. The Guardian HIE enables health information to be exchanged electronically between disparate healthcare information entities and systems while ensuring information integrity. The Interoperability, analytic intelligence functions, and exchange interfaces of the Guardian Platform reflect both the meaning and functionality of the concept of clinical integration.

The Guardian IT platform that facilitates referral management, secure messaging, beneficiary tracking, clinical data management, clinical integration, beneficiary communication, beneficiary and provider engagement, beneficiary care management and care coordination, and the compilation and reporting medical analytics. The platform enables providers to work together to exchange, discuss and track beneficiary information, strengthening relationships and revenue streams, leading to improved operational efficiencies and timely and meaningful clinical integration and continuity of care.

The Guardian IT platform and related Guardian Health Services are designed to:

• Promote true clinical integration and interoperability

• Facilitate enhanced use of evidence-based medicine

• Facilitate timely and efficient care coordination and care management

• Promote beneficiary, caregiver, and provider engagement

• Facilitate and support timely and accurate quality performance monitoring and reporting

VII. Guardian Driven Programs and Functions of the FPT Quality Assurance Program

The FPT Guardian IT platform drives a host of programs and functions that are directly responsive to the Medicare Shared Saving Program (MSSP) quality components of:

• Promotion of Medicare Beneficiary Engagement
• Promotion of Care Coordination
• Promotion of Evidence-Based Medicine
• Ensuring Accurate and Timely Reporting of Quality and Cost Metrics