CMS Announces GUIDE: A Medicare Dementia Care Model

On July 21, 2023, the Centers for Medicare & Medicaid Services (CMS) announced a new payment model for providers furnishing dementia care, called Guiding an Improved Dementia Experience (GUIDE). A wide range of Medicare Part-B providers and suppliers are eligible to participate, with the exception of durable medical equipment and laboratory suppliers. The model is a comprehensive package of person-centered assessments, care plans, and care coordination. Additionally, this new payment model aims to further enhance the quality of life for people living with dementia by improving dementia care, reducing strain on unpaid caregivers, and helping people with dementia remain in their homes and communities.

GUIDE’s approach to dementia care takes into account staffing considerations, quality standards, and services for beneficiaries and unpaid caregivers. Under the GUIDE model, beneficiaries are required to be screened for psychological and health-related social needs. As a GUIDE participant, providers are required to establish and maintain an interdisciplinary team consisting of a care navigator and a clinician, with the option of including additional members. The care navigator must have training in care planning and dementia assessment while the clinician is required to have dementia proficiency through experience caring for patients 65 years or older and for adults with cognitive impairment. GUIDE participants are required to provide support services alongside caregiver training.

There are two options for providers considering implementing GUIDE:

1. GUIDE participants already providing dementia care that are ready to immediately implement the new care delivery requirements
2. GUIDE participants without a current comprehensive dementia care program but who are interested in implementing such a program. These participants will receive support to enable them to better prepare for participation in the GUIDE model.

Unlike many CMS alternative payment models that are restricted or prohibited from concurrent participation in different payment models, GUIDE is compatible with other payment models. Such payment models include the Medicare Shared Savings Program (MSSP), Realizing Equity, Access, and Community Health (REACH), and some advanced primary care models. Additionally, GUIDE’s target population is Medicare fee-for-service beneficiaries as well as beneficiaries eligible for both Medicare and Medicaid.

As a GUIDE participant, the following payments can be received:

• Infrastructure Payment: A one-time, lump-sum infrastructure payment to support program development activities.
• Per-Beneficiary Per-Month Payment: A monthly per-beneficiary, per-month payment for caregiver education and support as well as for providing care management and coordination that will be subject to health equity and performance-based adjustments.
• Respite Care Payment: Ability to bill Medicare for respite services for beneficiaries with moderate to severe dementia and a caregiver with the goal of helping caregivers continue to provide care.

Healthcare providers interested in participating in GUIDE can submit letters of interest until September 15, 2023. GUIDE is expected to launch on July 1, 2024, and it will run for eight years.

For over 35 years, Wachler & Associates has represented healthcare providers and suppliers nationwide in a variety of health law matters, and our attorneys can assist providers and suppliers in understanding new developments in healthcare law and regulation. If you or your healthcare entity has any questions pertaining to healthcare compliance, please contact an experienced healthcare attorney at 248-544-0888 or wapc@wachler.com.