Submission For The Record of Paralyzed Veterans of America
Chairwowan Buerkle, Ranking Member Michaud, and Members of the Subcommittee, Paralyzed Veterans of America (PVA) would like to thank you for allowing us to submit a statement for the record on the issue of health care purchased by the Department of Veterans Affairs (VA) and delivered outside of the health care system—commonly referred to as fee-basis care. There is no doubt that fee-basis care provides an important tool to the VA in order to provide quality, timely health care services when those services are not readily available in the system or when that care is geographically inaccessible to a veteran.
As we have stated many times in the past, it is the position of PVA that the VA is the best health care provider for veterans. The VA’s unique “veteran specific” expertise is unrivaled. However, the VA serves a large veteran population with a myriad of complex medical needs, and when the VA is not able to provide that care it must partner with community providers through its Non-VA Care program.
The Non-VA care program provides contracted care services that are authorized at the discretion of VA leadership. The contracted services are reserved for veterans who have sustained a service-connected disability, or a disability for which a veteran was discharged or released from active duty, and provided when the VA is not capable of delivering the needed care, or such services are geographically inaccessible.
Over the years, PVA has remained concerned about the non-VA health care services provided to veterans as it relates to the VA’s ability to monitor the quality of care delivered, as well as the lack of a system to facilitate care coordination with non-VA providers so that veterans have a seamless exchange between the two systems. One mechanism used by the VA that began to address these concerns was the implementation of pilot project Health Care Effectiveness through Resource Optimization (Project HERO). The VA implemented Project HERO as a pilot in selected Veterans Integrated Service Networks (VISNs) to identify how a system could manage care that is provided through contracts with non-VA providers when the VA is not able to provide health care services to veterans. The pilot focused on objectives such as health care access, patient safety, and care coordination.
As the pilot is in its fifth and final year, the VA has identified the Patient Centered Community Care (PCCC) initiative and the Non-VA Care Coordination (NVCC) program to improve its Non-VA Care program. While the Project HERO pilot resulted in some positive outcomes and lessons upon which the VA can build an improved Non-VA Care program, PVA still has concerns regarding the implementation and management of the PCCC and NVCC programs. Most importantly, we remain concerned about the VA’s ability to monitor the quality of non-VA health care services, and coordinate care with outside providers.
Patient Centered Community Care (PCCC) and Non-VA Care Coordination (NVCC)
The VA describes the PCCC program as a centralized system to manage non-VA provider contracts. Specifically, through PCCC the VA intends to create a standardized contract referral process that will allow veterans to receive care outside of the VA, when necessary and authorized, in a timely and coordinated manner. In conjunction with PCCC, the NVCC program will focus on referrals for non-VA health care services. NVCC will also require that non-VA providers utilize required VA procedures and processes to allow for an exchange of information between providers and facilitate care coordination.
PVA appreciates that these two programs combined, in theory, address our concerns regarding the quality of non-VA purchased care and the VA’s ability to coordinate such care, and creates a permanent system to better manage non-VA contracted care. However, we believe that the success of PCCC and NVCC depends on the VA establishing systems that allow for a seamless exchange of information between non-VA providers and the VA, and the VA’s ability to collect data to measure the quality of non-VA care.
While the VA is in the implementation phase of re-creating its fee-basis care program, and has not yet commenced PCCC and NVCC in all VISNs, it also has not provided details on the systems that will need to be in place to guarantee care coordination. Of particular concern to PVA is the transition phase when Project HERO has ended and PCCC and NVCC are expected to begin. If these two programs are not fully implemented when Project HERO ends, what happens to those veterans already receiving care coordinated through Project HERO? Coordination of veterans care cannot be compromised during this transition.
One of the major components of PCCC and NVCC is having a system that allows for care-coordination. Care-coordination requires systems that exchange information that is timely and reliable. As the Project HERO pilot is ending, it is essential that VA ensure that the technological capabilities and the systems that are capable of sharing data, standardized templates, and programs with private providers are in place when PCCC and NVCC are implemented to coordinate care with community providers.
In order to support a system of care coordination between VA and community providers, a system for electronic information exchange must be a strong foundation. A primary goal for both the PCCC and NVCC programs should be to enable VA and non-VA providers to exchange information in a timely manner. Such information includes medical records, medical documentation, and payment information. If such a system for exchange of information is not available when the Project HERO pilot ends and these programs begin, then we believe the VA will be moving in the wrong direction.
It is also important to note that care coordination not only involves the VA and community providers, but must also include veterans. Veterans must have access to support services through the VA as they seek non-VA purchased care and referrals. As previously stated, PVA strongly believes that the VA is the best health care provider for veterans and as such we recommend that the NVCC program work closely with veterans’ Patient Aligned Care Teams to coordinate with community providers and ensure that veterans continue to receive their care through the VA health care system while receiving authorized treatments from outside (contract) providers.
Another serious concern for PVA is quality management. How will the VA manage the quality of care provided to veterans by non-VA providers? PVA believes that PCCC and NVCC programs must collect data on quality metrics such as patient satisfaction, safety and timeliness to adequately measure the quality of care provided by non-VA facilities. Such information not only serves as important metrics to identify areas for improvement, but also allows VA to hold private providers accountable for providing care that meets VA’s standards for quality. The VA must make certain that non-VA providers consistently provide veterans with timely, quality care that is patient-centric.
PVA understands that as the health care demands of veterans continue to evolve, and enrollment in VA’s health care system increases, so too does the need to partner with community providers. This partnership must be well managed, veteran-centric, and serve as a supplement to the quality of VA health services. PVA believes that the VA is moving in the direction of improving its non-VA purchased care program; however, many pertinent details are not in place. As the VA determines how to best implement PCCC, PVA believes that the VA must exercise its power to give final authorization to the providers with which it is entering contracts. Additionally, VA must determine the selection criteria to ensure that its quality standards for health care delivery are not compromised, and that the care provided meets VA’s other standards for safety and patient satisfaction.
Until PCCC and NVCC can be implemented with the systems that will allow electronic exchange of patient information and the collection of quality metrics, PVA recommends VA extend the Project HERO pilot program, and extend its existing fee-basis program as part of a continuing safety net for veterans. We also strongly encourage continued oversight from this Subcommittee to monitor the progress of the VA implementing these systems. Meanwhile, we must reemphasize that as the VA works to improve its purchased care and care coordination programs, foremost remains the fact that none of these initiatives should be designed to replace the high quality of care provided by the VA health care system. These programs should only serve to provide access to care where it is not readily available within the VA system.
Chairwoman Buerkle, and Members of the Subcommittee, once again PVA thanks you for holding this hearing on such an important issue for the many sick and disabled veterans who are unable to directly access VA facilities for their care. We also thank VA leadership for keeping veteran service organizations informed and involved during this process. We look forward to working with both the Subcommittee and VA leadership to improve the delivery of veterans’ health care services, whether those services are provided directly from VA, or through effective contract arrangements.
Information Required by Rule XI 2(g)(4) of the House of Representatives
Pursuant to Rule XI 2(g)(4) of the House of Representatives, the following information is provided regarding federal grants and contracts.
Fiscal Year 2012
No federal grants or contracts received.
Fiscal Year 2011
Court of Appeals for Veterans Claims, administered by the Legal Services Corporation — National Veterans Legal Services Program— $262,787.
Fiscal Year 2010
Court of Appeals for Veterans Claims, administered by the Legal Services Corporation—National Veterans Legal Services Program— $287,992.