ACUITY.health
The AI-Native Intelligence Layer for Value-Based Care
Core Positioning
"Renova delivers care — Acuity powers that care with precision."
We're not competing for patients. We're the technology and data platform that enables CCM, PCM, BHI, and RPM models to scale, automate, and improve ROI.
The Provider-Led VBE Model
A legally recognized network where providers form the contracting and governance entity
What Makes It Compliant
Provider-Led VBEs satisfy OIG/CMS 2020 Value-Based Safe Harbors and Stark exceptions, allowing providers to:
- • Coordinate care across all payer lines (Medicare, MA, commercial, Medicaid, employer)
- • Receive and distribute value-based payments
- • Collaborate with technology and operational participants without AKS/Stark violations
Compliance Foundation Requirements
| OIG Requirement | How Acuity's Model Meets It |
|---|---|
| Value-Based Purpose | Each VBE charter defines measurable purposes: improving quality, reducing unnecessary utilization, managing cost |
| Written Governance & Agreements | Providers hold majority control. Acuity supplies template charters and safe-harbor participant agreements |
| Contemporaneous Documentation | All activities recorded through Acuity's CHI provenance ledger — creating an auditable trail |
| Measurable Outcomes | Every participant's work tied to CHI metrics and quality indicators |
| Remuneration Rules | Payments are fixed-fee or performance-based — not tied to referral volume or payer flows |
Core Compliance Principle
"There can only be ONE source of truth — Acuity.health"
Every clinical, operational, and financial record that supports value-based payments must resolve to one authoritative dataset — Acuity's CHI computation layer.
VBE Scalable Architecture
Four-layer framework enabling infinite replication
A. Governance Layer
Provider Contracting Entity
- • Owns payer & employer contracts
- • Governs all participants
- • Maintains risk pools
- • Distributes savings
B. Intelligence Layer
Acuity.health
- • Single source of truth
- • QHIN/FHIR → CHI computation
- • Normalizes & measures performance
- • Manages compliance documentation
C. Operational Layer
Participants (Renova, etc.)
- • Deliver value-based activities
- • Care coordination
- • Patient engagement
- • Document in Acuity pipeline
D. Vendor Layer
Technology Partners (HPA, etc.)
- • Provide EMR/workflow tools
- • Commercial agreements only
- • No VBC payments
- • Outside VBE structure
Data & Interoperability Model
← One Source of Truth
The Compliant VBE Structure
Clean role separation under OIG 2020 Final Rule
| Player | Role | Legal Position | Revenue Stream |
|---|---|---|---|
| Provider Group | Contracting Entity / VBE Governing Body | Provider-led, risk-bearing | Shared savings, APCM, quality bonuses |
| Acuity.health | Technology + Analytics Infrastructure | VBE Participant (Data/Analytics) | Platform + performance-linked remuneration |
| Renova Health | Nursing / Care Coordination | VBE Participant (Operational) | Service remuneration under VBE safe harbor |
| HPA | Market Development & Relations | External Affiliate (NOT a VBE participant) | Business development fee or channel commission |
Acuity's OIG Safe Harbor Qualification
Care Coordination Safe Harbor (42 CFR §1001.952(ee))
Acuity qualifies as a VBE Participant providing in-kind remuneration through:
✓ Interoperability Tools
• QHIN/FHIR data exchange
• EHR integration
• Claims aggregation
• Unified data normalization
✓ Patient Engagement
• Digital twin platform
• CHI score transparency
• Care plan visibility
• Health education tools
✓ Cybersecurity
• HIPAA-compliant infrastructure
• Provenance ledgering
• Audit logging
• Data encryption
✓ Data Analytics
• CHI risk scoring
• Predictive modeling
• Outcome measurement
• Quality reporting
These tools directly advance the VBE's value-based purposes: coordinating care, improving quality, and reducing costs through appropriate utilization.
Critical: Data Flow & Payment Structure
All data MUST terminate in Acuity for normalization and measurement
1. Payers/CMS
Medicare, Medicare Advantage, and commercial payers send value-based payments directly to the Provider VBE. These include shared savings, APCM payments, quality bonuses, and risk-adjusted premiums. Only providers can receive these as the contracting entity.
2. Provider (VBE Lead)
The provider group holds all payer contracts and governs the VBE. They distribute payments to participants based on documented value-based activities. Pays Acuity for platform and analytics services. Pays Renova for care coordination work. All payments are performance-based or fixed-fee.
3. Renova to HPA
Renova pays HPA standard commercial fees for EMR services and workflow tools. This is a vendor relationship outside the VBE structure. HPA never receives value-based payments directly, maintaining clean compliance separation as they're not a VBE participant.
HPA's Strategic Role
Channel catalyst and provider liaison — NOT a VBE participant
Critical Distinction
HPA operates OUTSIDE the VBE compliance perimeter
Under OIG rules, VBE participants must directly perform measurable, outcome-driven activities. HPA's EMR and workflow tools only enable Renova's operations — they don't independently affect outcomes.
What HPA CAN Do
- ✓ Open doors to providers
- ✓ Broker introductions
- ✓ Provide EMR to Renova
- ✓ Generate care-gap analytics
- ✓ Channel partnership nationally
What HPA CANNOT Do
- ✗ Receive VBC payments directly
- ✗ Be a VBE participant
- ✗ Contract with payers for outcomes
- ✗ Bypass Acuity's data endpoint
- ✗ Define metrics independently
HPA's Revenue Model
- • Commercial fees from Renova
- • Business development commission
- • Performance-tied facilitation fee
- • Channel partnership revenue
- • NO shared savings or APCM
Strategic Positioning
"HPA's network is invaluable — you have the relationships and trust. Acuity brings the technology and compliance layer; Renova brings clinical coordination. Together, we help each provider form and own their own value-based enterprise."
Acuity: The Single Data Endpoint
All roads lead to one authoritative dataset for compliance and outcomes
OIG Compliance Requirement
"Acuity.health shall serve as the Data Custodian and Analytics Participant of the Value-Based Enterprise"
All clinical, operational, and claims data generated by Participants shall be routed to the Acuity platform for normalization, storage, provenance logging, and value-based performance measurement.
| Function | Acuity's Role | Compliance Benefit |
|---|---|---|
| Data Ingress | Ingest via QHIN/FHIR from all participants (HPA EMR, Renova, labs, payers) | Single audit point |
| Normalization | Apply FHIR primitives → CHI embeddings | Consistent metrics |
| Provenance | Timestamp and hash each transaction | Safe-harbor documentation |
| Computation | Run CHI arithmetic + transformer inference | Defensible outcomes |
| Reporting | Deliver to providers, payers, CMS via Acuity gateway | Traceable performance |
Why Multiple "Truths" Break VBEs
- • Conflicting outcome calculations
- • Payment disputes
- • Fragmented provenance
- • OIG audit risk
- • CMS non-compliance
- • Provider mistrust
Acuity's Single Truth Benefits
- ✓ One source of truth
- ✓ Outcome-linked remuneration proven
- ✓ No kickback risk
- ✓ Audit readiness
- ✓ Data-sharing clarity
- ✓ Provider maintains control
Provider-Led VBE Activation
Each provider becomes the contracting entity — owning their VBC destiny
The Activation Journey
Starting Point: Current State
Renova's existing patient panel represents a ready-to-activate population spread across multiple provider groups. Each group currently bills CCM independently, missing opportunities for PCM, RPM, and APCM revenue. These providers lack the infrastructure to transition to value-based contracts despite CMS incentives.
Initial Activation: Provider-Led VBEs
Each provider group becomes its own VBE contracting entity, maintaining autonomy while gaining infrastructure. Acuity provides the pre-built governance documents, compliance framework, and technology stack. Providers immediately begin capturing invisible clinical labor credits they've been missing, from CCM time increments to condition-specific PCM management.
Scaled Future: National Movement
The model replicates across regions as each successful VBE becomes a proof point for others. HPA's network accelerates adoption by introducing the proven framework to new provider groups. Within 12 months, dozens of provider-led VBEs operate independently yet share the same Acuity infrastructure, creating a national movement toward true value-based care.
The Pitch to Providers
"You'll own the contracts and the governance. We bring the pre-built VBE chassis, the compliance framework, and the technology stack to make it work instantly — no lawyers, no consultants, no new infrastructure."
Provider-Led VBE Benefits
For Providers
- ✓ Own their VBC contracts
- ✓ Control governance
- ✓ Regulatory protection
- ✓ Direct payer relationships
- ✓ Keep majority of savings
For Acuity
- ✓ Become VBE infrastructure standard
- ✓ Single source of truth position
- ✓ Scalable SaaS model
- ✓ No risk assumption
- ✓ Platform lock-in via CHI
For Renova
- ✓ VBE participant status
- ✓ Protected remuneration
- ✓ Expanded provider network
- ✓ Standard operational role
- ✓ Scale beyond CCM vendor
The CHI Engine: Your Provider Adoption Hook
Instant population understanding that proves the impact of invisible clinical labor
The Message to Physicians:
"CHI doesn't just show where patients are today — it proves your invisible clinical labor is working. Every phone call, every med review, every care coordination moment moves the CHI needle. CMS designed CCM to credit that work — CHI proves its impact."
Prevention work keeps them here — credit via AWV, preventive codes
Early intervention prevents chronicity — credit via TCM, RPM
Active management keeps stable — credit via CCM (time-based)
Focused coordination prevents crisis — credit via PCM (condition-specific)
Intensive management reduces admissions — credit via APCM (outcomes)
CHI Enables the Full CMS Ladder
CHI tracks every 20-min increment
CHI shows condition improvement
CHI proves outcome achievement
Overcoming Provider Objections
Positioning for Provider-Led VBE adoption with CMS credit optimization
"Why should we lead the VBE?"
Your Response:
"CMS designed these programs to credit your invisible clinical labor. As the VBE lead, you capture full value — from CCM time credits through APCM outcome payments — while we provide the infrastructure."
"We're already billing CCM"
Your Response:
"Great! You're getting credit for time. But are you capturing PCM for complex conditions? APCM for outcomes? Acuity helps you climb the entire CMS ladder from effort to impact."
"What about compliance risk?"
Your Response:
"Acuity automatically documents every billable moment of cognitive work — the calls, reviews, and coordination CMS wants to credit. Full OIG safe-harbor protection built in."
"How does this increase revenue?"
Your Response:
"Stack CCM + PCM + RPM + BHI, then graduate to APCM. CMS pays for the totality of care management — from 20-minute increments to reduced hospitalizations. CHI proves your impact."
The Credible Triad
- Renova acts as the sponsor and advocate
- Acuity acts as the platform
- HPA acts as the metrics verifier
Providers listen to credible triads.
The CMS Maturity Ladder
How CMS credits providers for the totality of care — from time to outcomes
CMS Is Paying for Invisible Clinical Labor
CMS knows that for patients with chronic conditions, a huge amount of meaningful care happens outside the exam room. They're crediting you for the time spent thinking about, reviewing, and managing patients — not just face-to-face encounters.
Chronic Care Management
Credit for TIME & EFFORT
Every 20-minute increment = payment for care coordination, phone calls, data review, medication reconciliation. The invisible work that keeps patients stable between visits.
Principal Care Management
Credit for FOCUSED MANAGEMENT
Payment for closely managing ONE high-acuity condition (CHF, COPD, CKD). Recognizes condition-specific oversight that prevents escalation.
Advanced Primary Care
Credit for OUTCOMES & IMPACT
Payment for results — continuous oversight, documented goals, improved trajectories. Not just time spent, but reduced hospitalizations and better control.
How Acuity Automates This Ladder
CCM Automation
Captures every phone call, chart review, and care coordination moment. Auto-documents 20-minute increments. Never miss billable time again.
PCM Tracking
Monitors specific conditions (CHF, COPD, diabetes). Shows medication adherence, symptom trends, and intervention success rates for each diagnosis.
APCM Achievement
Proves reduced hospitalizations, ER visits avoided, and improved patient control. CHI score changes document the impact of your care.
One Platform • All CMS Programs • Time to Value in 60 Days
CCM vs. True Value-Based Care
Moving from time-based credits to outcome-based value
CMS designed CCM to credit the invisible clinical labor — but true VBC rewards the results of that labor
Traditional CCM Model
Time → Payment
- ⏱️ 20-minute increment billing
- 💰 Fee-for-service codes (99490, etc.)
- 📈 Retrospective documentation
- 🎯 Credit for effort, not outcomes
- 📝 Episodic, patient-level focus
Acuity-Powered VBC
Time + Performance → Value
- 🌐 Full attributed population
- 💎 APCM + shared savings
- 🔮 Predictive CHI trajectories
- 🚀 Credit for reduced hospitalizations
- 🔄 Continuous improvement tracking
7 Ways Acuity Transforms Renova's Operations
From billing 20-minute increments to capturing total care value
Automatically document every phone call, data review, and care coordination moment that CMS designed CCM to credit — no more lost billable time
Move up the CMS maturity ladder: start with time-based CCM, add condition-focused PCM, graduate to outcome-based APCM — all on one platform
Prove you're not just spending 20 minutes — you're preventing hospitalizations. CHI trajectories give credit for outcomes, not just effort
Single interface for CCM, PCM, BHI, RPM — capture every billable moment of cognitive work that keeps patients stable between visits
Track documented goals, care plan monitoring, and improved trajectories — exactly what CMS requires for advanced primary care payments
Extend the invisible clinical labor through continuous patient engagement — every interaction credited and documented
Graduate from counting minutes to demonstrating reduced hospitalizations, improved control, and better adherence — the full CMS vision realized
Technical Architecture & Capabilities
🔄 Data Integration Layer
- • QHIN/Carequality Network
- • EHR Interoperability (FHIR)
- • Claims & ADT Feeds
- • RPM Device Integration
- • Social Determinants Data
🧠 AI/ML Engine
- • Multi-Agent AI Architecture
- • Continuous Health Index (CHI)
- • Predictive Risk Models
- • NLP for Clinical Notes
- • Trajectory Forecasting
⚡ Clinical Decision Support
- • Real-time Alerts
- • Care Gap Identification
- • Med Reconciliation
- • Evidence-Based Protocols
- • Automated Workflows
📊 Analytics & Reporting
- • Population Dashboards
- • Quality Metrics (HEDIS)
- • Cost Analysis
- • RAF Optimization
- • Contract Performance
The 10,000 Lives Opportunity
Even at this scale — it's a powerful proof point for a national model
Financial Impact Model
Why 10K Lives Is Significant
Statistical Validity
10k lives provides statistically stable actuarial baselines for predictive modeling and ROI demonstration
Contract Readiness
CMS and MA pilots often start with 5-10k lives — we're perfectly positioned for immediate launch
Proof Point
Enough volume to prove CHI stratification ROI in real-time with measurable outcomes
The Data Loop for Continuous Improvement
CHI predicts • Renova acts • Outcomes prove • HPA reports • Contracts expand
Transforming the Fragmented CCM Market
Current Market Reality
- Hundreds of CCM vendors doing compliance-level billing, not performance outcomes
- Each struggling to transition from fee-for-service to value-based contracts
- Lack population-level analytics and predictive intelligence
- Operating with fragmented data sources and no unified view
Acuity Provides
- ✓ Predictive CHI engine
- ✓ CDS + interoperability layer
- ✓ Digital twin engagement
- ✓ Measurable outcomes
- ✓ VBC operating system
Strategic Alliance Creates
- ✓ HPA brings network & relationships
- ✓ Renova provides care delivery
- ✓ Acuity powers intelligence
- ✓ Scalable across CCM vendors
- ✓ Unified VBC ecosystem
VBC Accelerator Implementation
Phase 1: Foundation
Months 1-2
- • Renova data integration
- • CHI baseline scoring (10k lives)
- • Provider group mapping
- • Initial dashboards deployed
- • HPA metrics integrated
Phase 2: Optimization
Months 3-4
- • Provider rollout (first 3 groups)
- • CDS workflow integration
- • Care team training
- • Performance benchmarking
- • ROI demonstration
Phase 3: Scale
Months 5-6
- • Full provider network live
- • Digital twin deployment
- • Contract negotiations
- • Expand to HPA network
- • Regional payer engagement
Projected Outcomes
The Endgame
- All 10,000+ patients risk stratified instantly
- Aggregate CHI data across the Renova network creates unified analytics
- Renova transitions from service organization to VBC-enabled network
- Every provider group becomes a new Acuity client node
- 5 provider groups today → 15 tomorrow → 50+ in 12 months
Why Acuity Is the VBC Operating System
Automating the full CMS maturity ladder from time credits to outcome payments
CMS's Vision, Realized Through Acuity
CMS created CCM to credit invisible clinical labor. PCM to reward focused management. APCM to pay for outcomes. Acuity is the only platform that automates this entire ladder — capturing every moment of cognitive work and proving its impact through CHI.
You're End-to-End Infrastructure
- • Capture every billable CCM minute
- • Track PCM condition improvements
- • Prove APCM outcome achievement
- • CHI shows the impact of invisible labor
- • Single platform for all CMS programs
- • Automated documentation & compliance
Income Trajectory
- • Start: Bill CCM time increments
- • Add: PCM for complex conditions
- • Stack: RPM + BHI + TCM codes
- • Graduate: APCM outcome payments
- • Scale: Shared savings & risk contracts
- • Result: 3-5X revenue per patient
The Win-Win Framing
"Every phone call, every data review, every care coordination moment has value. CMS designed these programs to credit that invisible work. Acuity ensures you capture every dollar you deserve — from 20-minute increments to reduced hospitalizations."
In One Line
"Acuity transforms invisible clinical labor into visible, billable, provable value — the full CMS vision from effort to impact."
Build the National Provider-Led VBE Movement
Transform Invisible Labor Into Visible Value
Every phone call matters. Every data review counts.
Every care coordination moment has value.
Acuity captures it all — from CCM minutes to APCM outcomes.
The Provider-Led VBE Stack
Provider: Owns contracts & captures full value
Acuity: Proves the impact of invisible labor
Renova: Delivers the credited care
HPA: Scales the model nationally
CMS Designed the Programs — We Built the Platform
From 20-minute CCM increments to APCM outcome payments,
Acuity ensures providers capture credit for the totality of
ongoing, proactive care management.
Next Steps
- • Map current CCM/PCM billing gaps
- • Calculate APCM revenue opportunity
- • Finalize VBE documentation
- • Identify first 5-7 provider groups
- • Launch with immediate ROI
One Source of Truth.
One Platform.
Full CMS Credit Capture.