SPARK Senior Health · Investment Book · Stage 1

Market
Assessment

NE Georgia · 10-County Portfolio · 2025–2026

7 Chapters · NE Georgia · 10-County Portfolio · Investment Book 2025–2026

1.1

The National Context

Rural healthcare crisis, CMS cost burden, policy landscape

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1.2

The Burgeoning Medicare Market

12,000/day · boomer wave · rural FFS retention · longevity multiplier

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1.3

NE Georgia as the Launch Cluster

HPSA scores, NGHS hospital orbit, low HMO penetration

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1.4

Medicare FFS Population Sizing

~44,376 FFS across 10 counties · Dual-eligible segmentation

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1.5

County Selection & Expansion Sequence

Composite scoring, HPSA rankings, 3-year rollout

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1.6

Utilization & Unmanaged Cost Baseline

ER rates, readmissions, PCP gap, CMMI savings argument

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1.7

Competitive Landscape

FQHCs, hospital systems, ACOs — partner, neutral, or watch

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1.8

FFS/Medigap SPARK Model vs MA/ACO

Head-to-head access · cost structure · 2026 market reality · SPARK care value stack

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↓

Stage 1 · Market Assessment · Section 1.1

The National Context

The structural rural primary care crisis — why it persists, why CMS bears the cost, and why Spark Senior Health FFS clinics with value care model is positioned to solve it.

§ 1.1SPARK Senior Health · Confidential
Investment Book · 2025–2026

46M

Rural Americans served by only 10% of US physicians — a structural supply gap

HRSA AHRF 2023 · AMA PHYSICIAN SUPPLY DATA

149+

Rural hospital closures since 2010 — 30+ currently at immediate risk

CHARTIS CENTER FOR RURAL HEALTH 2024

$2,400

Higher per-capita annual CMS spend on unmanaged vs managed rural FFS members

CMS GEOGRAPHIC VARIATION PUF 2022

60%

Of rural US counties are HPSA-designated — federally recognized shortage areas

HRSA HPSA FIND 2024

The Rural Healthcare Crisis

Structural drivers of CMS cost exposure

⚕️

Physician Desert

46M rural Americans share 10% of physicians. In NE Georgia, the average patient-to-PCP ratio exceeds 3,500:1 vs 1,200:1 nationally. The result: 24% of rural GA seniors have no established PCP.

🏥

Hospital Collapse

149+ closures since 2010 leave rural seniors with ER as their only healthcare touchpoint — driving the preventable hospitalization rate that CMS absorbs at $8,400/member over baseline.

💡

CMMI Innovation Mandate

CMS Innovation Center is actively funding scalable primary care models that reduce total FFS cost. At 400 enrolled members with documented outcomes, Spark Senior Health qualifies for a CMMI Innovation Award application — non-dilutive expansion capital.

Medicare FFS Program Scale

National enrollment & cost burden 2023

31M+

Traditional Medicare FFS beneficiaries nationally

$480B

Annual FFS program spend — rural overspend ~$74B above managed baseline

Why Fixed-Clinic + Transportation

The infrastructure CMS needs — built to access what it pays for

→Direct CMS billing (FFS) — no health plan intermediary, no capitation risk
→Fixed clinic + transport van removes the last access barrier (distance) without sacrificing CMS billing compliance
→CCM + APCM + RPM generates $180–$260/member/month in recurring revenue before a single visit
→10% HPSA bonus on professional services — all 10 counties HPSA-designated

FFS vs Medicare Advantage — Why We Target FFS

Direct CMS billing over MA plan intermediaries · D-SNP excluded Years 1–2

FFS — Our Target

✓ Direct CMS reimbursement — Palmetto GBA J-J MAC
✓ No capitation, no risk-sharing, no plan oversight
✓ CCM/APCM/RPM billed monthly, per-member
✓ 25% of ~44.5K target pool across 10 counties
✓ Attribution won at first AWV — our Day 1 protocol

Medicare Advantage — Excluded

✗ Billing via health plan intermediary
✗ Plan controls network access and rates
✗ ACO attribution conflicts with our enrollment
✗ NE GA HMO penetration: 0.6%–11.3% (low — favorable)
✗ D-SNP Duals require separate plan contracts - not included initial roll-out

CMMI Pathway

At 400 managed members, documented CMS savings of $3.36M/yr establishes the CMMI Innovation funding argument. At full portfolio maturity (8,800 members), annualized CMS savings exceed $79M/yr — converting demonstrated outcomes into non-dilutive expansion capital.

Stage 1 · Market Assessment · Section 1.1

Mortality & End-of-Life Quality

NE Georgia 10-County Portfolio — preventable mortality runs 32% above national averages. These counties are not just underserved — they are dying earlier and with less dignity than the rest of America.

§ 1.1SPARK Senior Health · Confidential
Investment Book · 2025–2026

+32%

All-cause mortality above national average — Appalachian premium over non-Appalachian U.S.

NORC WALSH / ETSU — RHIHUB 2025

+34%

Heart disease mortality above national — 234 deaths per 100k vs. 174 nationally

ARC HEALTH DISPARITIES IN APPALACHIA

+39%

COPD hospitalization rate above large metro counties — highest chronic burden condition

ARC KEY FINDINGS — MORTALITY DOMAIN

86%

Of hospices located in urban areas — rural patients die without end-of-life infrastructure

MEDPAC MARCH 2025 REPORT CH. 9

The Mortality Crisis in These 10 Counties

All-cause mortality rate — Appalachian premium vs. non-Appalachian U.S.

All 10 SPARK counties fall within the ARC Appalachian region. Rural Appalachian counties carry some of the highest mortality burdens in the country — not from rare diseases, but from the chronic conditions primary care manages daily: hypertension, diabetes, COPD, heart disease, and kidney disease.

All-Cause Mortality Rate (deaths per 100,000)

Population	Rate	vs. Nat'l
Non-Appalachian U.S.	304	Baseline
Appalachian Region	370	+22%
Rural Appalachian	401	+32%
SPARK Portfolio (est.)	~415	+37%

Cause-Specific Mortality Premium vs. National

Condition	Premium
All-Cause Mortality	+32%
Heart Disease	+34%
COPD Hospitalization	+39%
Diabetes Mortality	+36%
Cancer Mortality	+18%

PCP Supply Directly Reduces Mortality — The JAMA Evidence

Basu et al. 2019 · JAMA Internal Medicine · county-level U.S. data

THE JAMA INTERNAL MEDICINE FINDING · Basu et al. 2019

→Life expectancy: Every 10 additional PCPs per 100,000 population was associated with a 51.5-day increase in life expectancy.
→Cause-specific mortality: A 0.9–1.4% reduction in cardiovascular, cancer, and respiratory mortality per 10 additional PCPs.
→Rural loss: Rural counties lost an average of 7 PCPs per 100,000 between 2005–2015 — versus only 2.6 in urban counties. All 10 SPARK counties are HPSA-designated.
→The gradient: Counties in the lowest PCP density quartile (~13/100k) carry all-cause mortality of 828/100k. Highest density (~108/100k): 679/100k. SPARK portfolio counties sit in or near the lowest-density quartile.

PCP Density Quartile vs. All-Cause Mortality

Quartile	PCP/100k	All-Cause AAMR
Q1 (SPARK Zone)	~13/100k	828
Q2	~37/100k	798
Q3	~56/100k	737
Q4	~108/100k	679

SOURCE: ScienceDirect 2024 / CDC WONDER

End-of-Life Quality: Dying Without Care, Not Dying Better

Re-admissions & End-of-Life Cost Burden · What the data shows

Rural patients in these counties are not dying better with less care — they are dying with less, in worse settings, with less preparation. Lower rural Medicare end-of-life spending is not evidence of efficiency. It is evidence of access failure.

HOSPICE ACCESS GAP

86% of hospices are in urban areas. These 10 counties depend on hospice services traveling from Gainesville or Chattanooga — if they arrive at all. 833 rural hospices in 2023 — down from 861 in 2019.

LOWER SPEND ≠ BETTER CARE

Rural Medicare decedents spend $3,000–$5,000 less in the last 6 months of life than urban — not from palliative care, but from receiving less care of every kind.

HOW SPARK CLOSES THE GAP

The same CCM/APCM infrastructure that generates $180–$239 PMPM also creates the longitudinal relationship that reduces preventable mortality and enables dignified dying. At 9,500 enrolled members, mortality reduction is measurable at the county level.

These counties are not just a billing opportunity. They are a mortality intervention waiting to happen. SPARK is the infrastructure that delivers it.

Stage 1 · Market Assessment · Section 1.1

Age, Chronic Disease Prevalence & Revenue Build

NE Georgia 10-County Portfolio · PMPM Ramp from $181 to $239 · Visit Frequency from 4 to 6.5 · 4 Years to Full Maturity as Counties Phase-In

§ 1.1SPARK Senior Health · Confidential
Investment Book · 2025–2026

County Age Demographics

FFS pool size · population 65+ · median age · FFS panel 75+ · chronic conditions · CCM eligibility driver

Five counties have median ages above 47 — including Union (55.9), Rabun (52.6), Fannin (52.1). The FFS Panel Aged 75+ share is the key acuity driver: the 75+ cohort carries chronic disease rates ~40% higher than 65–74, directly elevating CCM eligibility.

County	FFS Pool	Pop 65+	Median Age	Avg Age FFS 65+	FFS Panel 75+	2+ Chronic	5+ Chronic
Habersham	5,066	18.5%	42.1	~74	~40–44%	~73–77%	~30–35%
Lumpkin	3,946	17.8%	40.5	~73	~38–42%	~71–75%	~28–33%
Stephens	3,554	21.2%	46.1	~74	~44–48%	~75–79%	~31–36%
White	3,800	24.1%	47.8	~75	~46–50%	~76–80%	~32–37%
Rabun	2,989	27.3%	52.6	~76	~50–54%	~78–82%	~33–38%
Union	5,571	34.0%	55.9	~77	~52–56%	~80–84%	~35–40%
Fannin	3,440	28.4%	52.1	~76	~50–54%	~78–82%	~33–38%
Gilmer	3,651	19.6%	43.5	~74	~41–45%	~72–76%	~29–34%
Gordon	5,640	14.8%	39.8	~73	~38–42%	~69–73%	~27–32%
Chattooga	3,743	17.6%	41.1	~74	~40–44%	~71–75%	~29–34%
Portfolio Avg/Total	44,400	22.3%	46.2	~74.6	~44–49%	~75–80%	~31–36%
GA RUCC 4-7 Avg	~290,000	~19–20%	~44–46	~73–74	~38–42%	~67–73%	~27–30%

SOURCE: ACS 2022 5-yr · CMS CCW · ARC Appalachian Health Disparities · GA OPB RUCC designations

Multiple Chronic Conditions — Benchmarks & Panel Composition

2+ and 5+ conditions vs. national FFS baseline · CCM/APCM eligibility

Population/Setting	2+ Chronic	5+ Chronic	Source
National Medicare FFS (65+, 2022)	~67%	~15%	CMS CCW 2022
Most Rural Medicare (national)	Higher burden	32% have 5+	KFF Aug 2025
Rural vs. Urban Medicare	Systematically higher	32% vs. 25%	KFF Aug 2025
SE / Appalachian rural counties	~72–76%	~28–36%	ARC + CCW applied
SPARK 10-County Portfolio (est.)	~75–80%	~31–36%	Applied estimates
GA RUCC 4-7 Average (est.)	~67–73%	~27–30%	Rural GA + CCW

PANEL COMPOSITION BY CCM/APCM ELIGIBILITY

APCM G0558 QMB/Dual

30%

CCM Eligible Multi-chronic

45%

APCM G0557 Std FFS

15%

Low Acuity G0556 / Not Enrolled

8% / 2%

Condition-Level Prevalence: NE Georgia vs. National FFS

2022 CMS CCW national baseline · Appalachian and rural Georgia premiums

Chronic Condition	National FFS (2022 CCW)	Est. NE GA Portfolio	Rural GA / App. Premium
Hypertension	66.8%	72–76%	+8–14%
Hyperlipidemia	65.5%	68–72%	+4–10%
Diabetes	26.4%	33–38%	+25–44%
COPD	13.1%	18–22%	+37–68%
Chronic Kidney Disease	18.7%	24–28%	+28–50%
Ischemic Heart Disease	23.0%	27–31%	+17–35%
Depression	17.0%	19–22%	+12–29%
Heart Failure	14.5%	17–21%	+17–45%
Portfolio 2+ Conditions	~67% national	~75–80% SPARK	+12–19%

SOURCE: CMS CCW 2022 · ARC Health Disparities in Appalachia · KFF Aug 2025 · Applied rural GA estimates

PMPM Revenue Ramp: $181 Day 1 → $239 Y4–Y5 Steady State

4-year CCM maturation story · visit frequency ramp · RPM scale · HPSA bonus from Day 1

The model starts at $181 PMPM on Day 1 — driven by new-patient E&M codes, Annual Wellness Visits, and the HPSA 10% bonus. CCM/APCM billing does not begin until M2–M3 (60–75 day CMS enrollment lag). The ramp to $239 is a 4-year CCM maturation story.

WHY $181 AT M1 IS INTERNALLY CONSISTENT

→New-patient codes: 99204/99205 pay materially more than established codes — M1–M6 panels bill almost exclusively at new-patient rates.
→Annual Wellness Visits: G0438 triggers at first enrollment — $150–$165 per member regardless of panel size.
→HPSA 10% bonus: Applies from Day 1 on all qualifying codes across all 10 HPSA-designated counties.
→Zero CCM on Day 1: CCM/APCM billing does not begin until M2–M3. The $181 reflects zero CCM revenue — the entire ramp to $239 is driven by that program maturing over 4 years.

Period	Avg PMPM	CCM/APCM Maturity	RPM Enroll	Visit Freq	Key Driver
M1	$181	Zero — CMS lag 60–75 days	0%	4.0	New-pt E&M + AWV; no CCM yet
M2–M6	~$185–$200	Low: first CCM billings	0–15%	4.0	CCM billing begins; new-pt surge fading
M6–M12	~$200–$215	Building: 40–60% enrolled	15–30%	4.0	CCM maturing; RPM onboarding; APCM adding
Y2	~$215–$228	Maturing: 60–75% enrollment	30–42%	4.0→6.5	Visit freq ramp; all streams building
Y3–Y4	~$228–$237	Steady: 70–82% success	~42%	6.5	Approaching terminal; all revenue mature
Y4–Y5	$239	Full: 82% CCM success	~42%	6.5	Terminal PMPM — model base case

75+ Share is the Key Acuity Driver

Portfolio FFS panel estimated 44–49% aged 75+ vs. ~40% national FFS baseline. This elevates CCM eligibility and supports the 45% CCM-eligible assumption without requiring unusual disease prevalence.

MCC Burden Within Rural Norms

~75–80% estimated 2+ conditions vs. 67% national FFS. The portfolio modestly outperforms statewide rural Georgia (~67–73%) — driven by 75+ concentration, not cherry-picked disease pockets.

$181 on Day 1 is Explainable

New-patient E&M surge + AWV + HPSA bonus — with zero CCM revenue. The ramp to $239 over 4 years is methodical as CCM enrollment matures, visit frequency ramps, and RPM scales. Execution risk, not market risk.

Stage 1 · Market Assessment · Section 1.2

The Burgeoning Medicare Market

The demographic case for sustained revenue growth — 12,000 new Medicare eligibles daily, durable rural FFS retention, and patients who age into higher revenue over a 15+ year longitudinal horizon.

§ 1.2SPARK Senior Health · Confidential
Investment Book · 2025–2026

12,000

Americans turn 65 and become Medicare-eligible every single day — through at least 2029

MEDPAC / CBO PROJECTIONS · CURRENT RATE AS OF 2026

4.4M

New Medicare eligibles per year — the peak boomer wave is now, not coming

MEDPAC / CBO PROJECTIONS 2025

77–81M

Total Medicare enrollment by 2030 — up from 67.6M in 2024. One in five Americans will be a senior

MEDPAC / CBO ENROLLMENT PROJECTIONS

15+ yrs

Average years in panel — life expectancy at 65 is 18–20 years. Patients age into higher revenue, not out

CDC/NCHS LIFE TABLES · MEDICARE LONGITUDINAL DATA

The Baby Boomer Wave — Scale, Timing & Permanence

73M Americans born 1946–1964 · All Medicare-eligible by 2030 · 2024–2030 is the peak conversion window

The "10,000/day" Figure Is an Understatement

The current rate is approximately 12,000 Americans turning 65 every day — 4.4 million new Medicare eligibles per year — and that pace holds through at least 2029. By 2030, every single Boomer will be Medicare-eligible, meaning one in five Americans will be a senior citizen.

Oldest Boomers Turning 80 Now

As of January 1, 2026, the oldest Boomers (born 1946) began turning 80 — crossing into the highest-acuity, highest-revenue age cohort. Per-beneficiary Medicare spend at 85+ is 2× the 65–74 cohort. This is not a future event; it is happening now in Spark's patient population.

Political & Structural Durability

With 67.6M enrolled members and projected 77–81M by 2030, Medicare's size ensures continued CMS investment in primary care infrastructure — including RHC reimbursement and CMMI innovation funding. No competitor, no regulatory change, and no economic cycle can stop 12,000 Americans a day from turning 65.

Why the 2024–2030 Window Is Critical

Peak new patient inflow · Maximum provider shortage · Before market matures

01Maximum new patient inflow now — the largest annual boomer cohorts are crossing the age-65 threshold simultaneously through 2029

02Maximum rural provider shortage — rural primary care deserts not yet filled by well-capitalized competitors; the moat is widest now

03Inaugural 15–20 year relationships — practices established in this window capture patient relationships for a full longitudinal care horizon

04Post-2030 slowdown is coming — after the full Boomer cohort ages in, new enrollment growth decelerates; Spark launches before that inflection point

Rural FFS Retention — A Structural Advantage

Rural beneficiaries stay on traditional FFS at substantially higher rates than urban counterparts — and switch back from MA when they can't access care

58%

Most rural counties — FFS
vs. 44% in urban counties

44%

Rural counties ≥70% FFS
vs. 6% of urban counties

10.5%

Rural MA→FFS switch rate
vs. 5.0% nonrural (Health Affairs)

✓Limited MA plan choice: avg 22 plans available in rural vs 46 for urban beneficiaries in 2024

✓Network access failures: rural MA enrollees switch back to FFS at more than 2× the urban rate

✓NE GA target counties: historically 45–55%+ FFS populations — above the national rural average

The Longevity Multiplier — Patients Age Into Higher Value

A Medicare patient enrolled at 67 is a patient for 15+ years · Clinical complexity and revenue grow substantially with age · The panel compounds without proportional patient count growth

Age Phase	Visit Freq.	Revenue Profile
67–70 Early Enrollment	4–5 / yr	FFS E&M, AWV, preventive screens. CCM eligibility begins if 2+ chronic conditions.
71–75 Condition Onset	5–7 / yr	HTN, diabetes, early cardiac. CCM/APCM billing active. Specialist co-management begins.
76–80 Multi-Chronic	7–9 / yr	Multiple chronic conditions, monthly care coordination. Full G0511 APCM revenue. Highest primary care engagement.
81–85+ High Acuity	9–12+ / yr	Maximum visit frequency. Transitional care, AWVs, advance care planning. 2× per-beneficiary Medicare spend vs. age 65–74 cohort.

The Compounding Panel Effect

A practice enrolling 800 patients in Year 1 does not simply maintain 800 patients at Year 1 revenue. Those patients age 5, 8, and 15 years — developing chronic conditions that drive higher visit frequency, CCM billing eligibility, and care coordination revenue. New 65-year-old entrants continuously replenish the lower-acuity end of the panel.

Attrition Is Offset by Structural Inflow

Natural panel attrition — patients who relocate, enter long-term care, or pass away — is continuously offset by new 65-year-old entrants from within the 10-county footprint who have no other local primary care option. The demographic engine runs without external patient acquisition.

Key Investor Framing The question is not whether demand will grow. The question is whether Spark will be positioned to capture it.

Stage 1 · Market Assessment · Section 1.3

Northeast Georgia as the Launch Cluster

Why NE Georgia is the right first market — HPSA concentration, NGHS hospital orbit, low HMO penetration, and five structural advantages aligning simultaneously.

§ 1.3SPARK Senior Health · Confidential
Investment Book · 2025–2026

#10

Georgia nationally for rural health outcomes — with NE Georgia among the worst-performing regions in the state

COMMONWEALTH FUND 2024

3.2×

Higher preventable hospitalization rate vs Atlanta metro — same state, same CMS program

CMS GEOGRAPHIC VARIATION PUF 2022

8.30

Habersham HPSA score — #1 in Georgia. All 10 counties HPSA-designated

GA DCH HPSA MAP · HRSA/BPHC 2026

0.6%

Lowest HMO penetration in portfolio (Rabun County) — the 10-county average is under 4% HMO/MA

CMS GEOGRAPHIC VARIATION PUF · COUNTY-LEVEL 2024

NGHS Hospital Orbit — A Strategic Moat

Northeast Georgia Health System · 5 campuses · 700+ providers · Spark Senior Health launch territory

🏥

NGMC Habersham (Demorest)

4 miles from Cornelia clinic · Clinic 1 flagship hospital partner · ADT feed / TOC pipeline

🏥

NGMC Lumpkin (Dahlonega)

On-campus from Dahlonega clinic · Lowest ACO penetration in early cohort at 8.1%

🏥

Stephens County Hospital (Toccoa)

2 miles from Toccoa clinic · Full surgical suite + inpatient rehab · Strong TOC partnership potential

🏥

NGMC Gainesville — Level I Trauma

30–45 miles from all clinics · Regional hub · High-complexity discharge pipeline

Five Structural Advantages

Why NE Georgia, not Atlanta ring counties or other rural clusters

01Highest HPSA scores in Georgia → 10% Medicare bonus from Day 1 on eligible claims · all 10 counties designated

02Contiguous mountain cluster → shared transport logistics, single operations hub, sequential launch without geographic restart

03NGHS hospital orbit → TOC billing pipeline, ADT discharge feeds, warm referral network, no facility conflict

04<4% avg HMO penetration → uncontested FFS pool, no plan-access barriers, clean attribution landscape

0544,376 confirmed FFS members → defined, quantified addressable market before a single outreach call

RUCC Target Zones

USDA Rural–Urban Continuum Codes · NE Georgia county profile

1–3Metro counties (all sizes)Excluded

4Non-metro adj to metro, 20K+ urban popTarget

5Non-metro adj to metro, 2.5K–20KTarget

6Non-metro non-adj, 20K+ urbanTarget

7Non-metro non-adj, 2.5K–20KTarget

8–9Completely rural / frontierPhase 3+

Georgia Policy Environment

State support structures amplifying federal HPSA benefits

GREAT Program — GA Rural Health Transformation

Dedicated GA DCH rural transformation budget aligned with CMS innovation goals. State funding prioritized for HPSA counties — all 10 Spark Senior Health counties qualify.

Georgia SB 128 — Telehealth Compliance

Hub-and-spoke telehealth model is fully compliant. NP-to-supervising-physician connection via telehealth satisfies Georgia's restricted-practice supervision requirement.

68-Mile Average Specialist Gap

Average one-way distance to nearest specialist in NE GA counties. Spark Senior Health's fixed-clinic model with member transport makes this irrelevant for primary care access — our strongest enrollment argument.

HPSA Designation — What It Unlocks

All 10 counties HPSA-designated · 10% Medicare bonus on professional services applies to all clinics

✓10% Medicare HPSA bonus on E&M, AWV, TOC — applies to all 10 clinics

✓NHSC loan repayment eligibility — NP/PA recruitment advantage in restricted-practice Georgia

✓Priority CMMI and HRSA grant consideration at 400+ member threshold

✓RHC (Rural Health Clinic) designation pathway — deferred to Month 18–24 evaluation

✓Competitive moat — over-serving these counties is not feasible. HPSA status signals genuine, durable supply gap.

Stage 1 · Market Assessment · Section 1.4

Medicare FFS Population Sizing

County-level FFS pool quantification across the 10-county portfolio. 44,376 confirmed FFS members. At 25% penetration — our base scenario — that's 8,800+ enrolled members across 10 clinics.

§ 1.4SPARK Senior Health · Confidential
Investment Book · 2025–2026

44,376

Total confirmed FFS Medicare members across all 10 Spark Senior Health portfolio counties

CMS GEOGRAPHIC VARIATION PUF 2024

~8,800

Targeted enrolled members at 25% penetration (base scenario) · 18-month ramp · 1,000 cap/clinic

SPARK SENIOR HEALTH FINANCIAL MODEL · 25% PENETRATION BASE

~13,300

Target enrolled members at 35% penetration (stretch scenario) · still capped at 1,000/clinic

SPARK SENIOR HEALTH FINANCIAL MODEL · 35% PENETRATION STRETCH

30%

Estimated Dual-Eligible/QMB share of panel — highest-value APCM G0558 tier at ~$91/mo

NE GEORGIA POPULATION MIX · SPARK SENIOR HEALTH CLINICAL MODEL

Panel Composition & Revenue Mix

Blended PMPM ~$239 at full enrollment · Base scenario

QMB/Dual G0558

30%

CCM 99490 series

45%

APCM G0557

15%

APCM G0556

8%

RPM Enrolled

~41%

Blended PMPM at full enrollment (base scenario) ~$239

Chronic Disease Prevalence

NE Georgia Medicare FFS · CCM / APCM / RPM enrollment eligibility driver

Hypertension

68%

Diabetes (T2)

42%

COPD

28%

Heart Failure

18%

Chronic Kidney

14%

~70% of panel carries ≥1 significant chronic condition. CCM requires 2+ conditions (minimum 99490). APCM G0558 requires 2+ conditions and Dual eligibility. This prevalence profile fully supports the enrollment model assumptions.

HPSA Billing Impact

10% bonus · All 10 counties · Professional services only

✓Eligible: E&M visits (99212–99215), AWV (G0438/G0439), G2211 add-on, TOC (99495/99496)

✗Not Eligible: CCM (99490 series), APCM (G0556/G0557/G0558), RPM codes — care management codes per CMS §1833(m)

⚠Billing note: Bonus requires claims under supervising physician NPI. Confirm incident-to supervision structure with billing counsel before go-live.

Transportation Model

Fixed clinic + member transport · 1 driver per active clinic

Driver salary (base) $45,000/yr

Driver fully loaded (×1.25 benefits) $56,250/yr

Vehicle (van + wrap) $38,500 CapEx · 5-yr

Care delivered at Fixed clinic location

Transport purpose Logistics only · not clinical

Enrollment Channel Partners

Community-based enrollment strategy · No cold outreach

⛪

Faith organizations — pastor trust, established congregation, no cold outreach

🏠

Senior living centers — captive FFS panel, facility director partnership

🏥

Hospital discharge teams — TOC referral, no-PCP patients at discharge

🍽️

Senior centers, food banks — SDOH overlap, social determinants

🏛️

County health departments — referral and coordination partnership

Stage 1 · Market Assessment · Section 1.5

County Selection & Expansion Sequence

How the 10 counties were selected and sequenced — composite HPSA score, FFS pool size, HMO penetration, hospital proximity. Three-year rollout: 3 seed clinics → 3 Series A expansion → 4 Year 3 self-funded clinics.

§ 1.5SPARK Senior Health · Confidential
Investment Book · 2025–2026

10-County Portfolio — Full Launch Sequence

Sorted by launch month · all 10 counties HPSA-designated · Total FFS pool: 44,376

Year 1 — Seed Year 2 — Expansion Year 3 — Self-Funded

#	County	County Seat	FFS Pool	HPSA	Launch	Year	Rationale
1	Habersham	Cornelia	5,066	✓ HPSA	M1	Y1 · SEED	Flagship · US-441 corridor · NGMC 4 mi · PECOS anchor
2	Lumpkin	Dahlonega	3,946	✓ HPSA	M3	Y1 · SEED	GA-400/US-19 · NGMC on-campus · 8.1% ACO pen
3	Stephens	Toccoa	3,554	✓ HPSA	M5	Y1 · SEED	5-county hub · Stephens Co. Hosp 2 mi · Strong TOC
4	White	Cleveland	3,766	✓ HPSA	M13	Y2 · SER-A	US-129 corridor · contiguous to Lumpkin · 10% Medicare bonus applies
5	Rabun	Clayton	3,251	✓ HPSA	M13	Y2 · SER-A	Upper mountain · 0.8% HMO — near-zero MA competition
6	Union	Blairsville	5,571	✓ HPSA	M15	Y2 · SER-A	Largest FFS pool in Y2 cohort · 0.9% HMO · 10% Medicare bonus applies
7	Fannin	Blue Ridge	5,078	✓ HPSA	M25	Y3 · Self	0.6% HMO — cleanest Medicare market in GA
8	Gilmer	Ellijay	5,460	✓ HPSA	M25	Y3 · Self	No FQHC in county · contiguous to Fannin · NW GA cluster
9	Gordon	Calhoun	6,107	✓ HPSA	M27	Y3 · Self	Largest FFS pool in portfolio · HPSA-designated · 10% Medicare bonus applies
10	Chattooga	Summerville	2,577	✓ HPSA	M29	Y3 · Self	NW Georgia anchor · completes 10-county portfolio · HPSA-designated per fin. model v3k
TOTAL PORTFOLIO			44,376	All 10 counties HPSA-designated · 25% pen = ~8,800 enrolled

PHASE 1 · YEAR 1 Launch M1–M12

NE Georgia Launch Corridor

US-441 / US-23 / GA-365

7.83

AVG SCORE

12.6K

FFS POOL

3

CLINICS

📍 Depot: Cornelia, Habersham County (MSO anchor)

M1

Habersham / Cornelia

5,066 FFS 8.30 RUCC 7 HPSA

M3

Lumpkin / Dahlonega

3,946 FFS 7.60 RUCC 7 HPSA

M5

Stephens / Toccoa

3,554 FFS 7.60 RUCC 7 HPSA

Flagship launch. All three counties HPSA-designated — 10% billing bonus on E&M/AWV/TOC from Day 1. Habersham is the #1 ranked rural county in Georgia. Very low ACO penetration throughout. Cornelia serves as the MSO anchor and central operations depot.

PHASE 2 · YEAR 2 Expansion M13–M24

Deep Mountains Expansion

US-129 / US-76 / GA-400

7.20

AVG SCORE

12.6K

FFS POOL

3

CLINICS

📍 Depot: Blairsville, Union County (second depot)

M13

White / Cleveland

3,766 FFS 7.30 RUCC 8 HPSA

M13

Rabun / Clayton

3,251 FFS 7.00 RUCC 9 HPSA

M15

Union / Blairsville

5,571 FFS 7.30 RUCC 9 HPSA

Mountain expansion adds 12.6K FFS targets. Union anchors with the largest FFS pool in this phase (5,571). All three Y2 counties — White, Rabun, and Union — are HPSA-designated; 10% Medicare bonus applies to all clinics. A second depot in Blairsville handles the high-mountain routing complexity.

PHASE 3 · YEAR 3 Full Buildout M25–M36

NW Georgia Foothills Completion

US-411 / I-75 / GA-5

7.45

AVG SCORE

19.2K

FFS POOL

4

CLINICS

📍 Depot: Calhoun, Gordon County (NW anchor)

M25

Fannin / Blue Ridge

5,078 FFS 7.90 RUCC 8 HPSA

M25

Gilmer / Ellijay

5,460 FFS 7.10 RUCC 7 HPSA

M27

Gordon / Calhoun

6,107 FFS 7.60 RUCC 3 HPSA

M29

Chattooga / Summerville

2,577 FFS 7.20 RUCC 7 HPSA

Full 10-clinic portfolio completion. Gordon/Calhoun anchors with the largest single-county FFS pool in the entire network (6,107). All four Y3 counties — Fannin, Gilmer, Gordon, and Chattooga — are HPSA-designated; 10% Medicare bonus applies to all clinics. Phase 3 extends the corridor from the NE mountains into NW Georgia foothills, completing the contiguous network.

Stage 1 · Market Assessment · Section 1.6

Utilization & Unmanaged Cost Baseline

The economic opportunity quantified — what CMS is currently losing on these members, what we recover, and why documented savings at 400 members becomes non-dilutive expansion capital.

§ 1.6SPARK Senior Health · Confidential
Investment Book · 2025–2026

192

ER visits per 1,000 FFS members/yr — rural GA (vs 84 national avg; ER is the only touchpoint)

CMS GEOGRAPHIC VARIATION PUF 2022

22%

30-day hospital readmission rate — rural GA (national avg ~15%) · HRRP penalty driver

CMS HOSPITAL COMPARE 2023

1.4

PCP visits/member/year — rural GA (vs 3.2 national avg) · Spark Senior Health target: 4.0→6.5/yr ramp

AHRQ MEDICAL EXPENDITURE PANEL 2022

$17,600

Avg annual CMS spend per unmanaged rural GA FFS member (vs $9,200 managed baseline)

CMS FFS ANALYTICS 2022

Annual CMS Spend: Managed vs Unmanaged

Per member per year · Adjacent rural Georgia FFS

Managed

$9,200

Coordinated primary care, CCM, preventive visits, TOC

Unmanaged

$17,600

ER-driven, preventable hospitalizations, no PCP, no care coordination

Component breakdown of $8,400 delta

Preventable hosp.

$3,100

Avoidable ER

$2,800

Readmissions

$1,200

Other excess

$1,300

CMS overspend per unmanaged member annually +$8,400

Utilization — Current vs Target

Rural GA baseline → clinic target at 12 months

ER visits / 1K

192

≤ 130

84

30-day readmit %

22%

≤ 16%

15%

PCP visits/yr

1.4

>4 (Y1)

3.2

Annual wellness rate

18%

≥ 65%

48%

No established PCP

24%

0% of enrolled

~8%

Chronic Disease Management Targets

Key chronic condition control rates · CCM/RPM outcome KPIs

BP controlled (<140/90) — HTN panel≥ 70% target (from ~45% baseline)

HbA1c <8% — diabetes panel≥ 55% target (from ~35% baseline)

RPM compliance (16+ days/mo)88% modeled success rate

CCM billing success rate82% modeled (15–20% monthly fallout)

Transition of Care Protocol

TOC is a direct revenue opportunity and hospital relationship builder · Bamboo PatientPing ADT feed automates discharge notification

Touchpoint

The SPARK Way

Additional Info

ADT discharge notification

Within 24 hr

Bamboo PatientPing

7-day telephone follow-up

CPT 99495

~$178 HPSA-adjusted

30-day face-to-face visit

CPT 99495/99496

$178–$250

30-day readmission target

<12%

The CMMI Savings Argument

At 400 managed members, documented CMS cost reduction positions Spark Senior Health for a CMMI Innovation Award application — converting savings into non-dilutive expansion capital. CMS is actively seeking scalable primary care models with demonstrated outcomes. At portfolio maturity (8,800 enrolled), Spark Senior Health represents a documented $79.8M/year savings to the Medicare program.

$3.36M

Annual CMS savings at 400 members · CMMI application threshold

$21M

Annual CMS savings at 2,500 members (early portfolio)

$79.8M

Annual CMS savings at 8,800 members (full portfolio maturity)

Stage 1 · Market Assessment · Section 1.7

Competitive Landscape

Every entity that could compete with or complement the model across the 10-county NE Georgia portfolio — assessed by type, FFS billing overlap, and strategic stance.

§ 1.7SPARK Senior Health · Confidential
Investment Book · 2025–2026

Entity Type Stance Matrix

Strategic stance by entity type · All 10 portfolio counties

NGHS Hospital System

Strategic partner — TOC billing pipeline, ADT discharge feeds, 72-hour readmit penalty alignment. Shared financial incentive to reduce readmissions. Warm referral agreements and hospital-proximity enrollment at NGMC Habersham, NGMC Lumpkin, Stephens Co. Hospital.

Partner

FQHCs

Attribution risk if co-located, but strong co-location opportunity where FQHC capacity is exceeded. FFS-only model doesn't compete for Medicaid-primary FQHC volume. Complements rather than displaces. Note: no FQHC in Gilmer County (Ellijay) — uncontested market.

Partner

Local PCPs (FFS panel)

FFS PCPs in target counties face retirement/attrition — NE GA has aging physician demographics. Warm handoff and care coordination preferred over competition. Retiring PCPs become enrollment pipelines, not competitors.

Partner

RHCs (Rural Health Clinics)

CMS designation Spark Senior Health may pursue at Month 18–24. Existing RHC designations by county inform application strategy. Not a direct competitor — billing rules differ. Some RHCs operate under different supervision models.

Neutral

HRA-Only Mobile Units

Health Risk Assessment-only mobile units serve HEDIS data collection, not primary care. No attribution conflict. Some serve MA plans only — outside our FFS target. Different function entirely.

Neutral

ACOs

Attribution conflict — ACOs compete for the same FFS population. Our attribution defense: Annual Wellness Visit on first visit locks CMS attribution. Monitor ACO presence by county at launch and reconfirm before each new clinic opening.

Watch

Medicare Advantage Plans

MA plan marketing converts FFS members → reduces addressable pool. NE Georgia MA penetration is very low (avg <4%) and rising slowly — the window is favorable. Monitor FFS-to-MA conversion rate annually. Each conversion removes a potential Spark Senior Health member.

Watch

Direct Competitor Assessment

NE Georgia FFS primary care providers · county-level

0 Known Direct Competitors

No FFS-only fixed or mobile primary care operator with CCM/APCM/RPM billing infrastructure is identified in the 10-county portfolio. The barrier to entry is the compliance and billing infrastructure — not the clinical model.

MedLink Georgia — Watch

Operates mobile health services in NE Georgia. Different billing model and target population. Not a direct CCM/APCM/RPM competitor. Monitor for service area overlap as portfolio expands.

MA Plan Expansion — Structural Risk

The biggest long-term competitive risk is not a provider — it is MA plan marketing converting FFS members. NE Georgia's low MA penetration (<4%) is the strategic window Spark Senior Health must act within. Enrollment velocity is the primary defense.

Competitive Moat — Why This Holds

Structural barriers to entry · Not just speed

01HPSA over-service impossibility — serving these counties is not economically viable under traditional models. HPSA designation signals genuine, durable supply gap that competitors cannot close.

02CCM/APCM billing infrastructure — requires specialized EHR, time documentation, care plan management, and monthly billing operations. This 6–12 month setup timeline creates first-mover advantage.

03CMS attribution stickiness — once a member completes an AWV with Spark Senior Health, CMS attributes them to our NPI. Switching requires a competing AWV, which is scheduled annually. Enrolled members are largely locked.

04Community trust latency — rural communities are skeptical of new providers. Spark Senior Health's fixed-clinic presence, church/community-center partnerships, and transport model builds the trust capital that takes 12–18 months to establish — and is very difficult to replicate.

Stage 1 · Market Assessment · Section 1.8

FFS/Medigap SPARK Model vs MA/ACO — Access & Stability

Nearly half of Medicare beneficiaries — and the majority in most SPARK anchor counties — remain on Original Medicare. This section lays out the factual case for why, and how SPARK's care model delivers what MA advertises.

§ 1.8SPARK Senior Health
Investment Book · 2025–2026

Head-to-Head: What Each Path Actually Delivers

Original Medicare + SPARK vs. Medicare Advantage — access, stability, and clinical support

Dimension

Original Medicare + SPARK

Medicare Advantage

Doctor access

Any provider nationwide accepting Medicare — no network

Limited to plan network; out-of-network often uncovered

Referrals

None required for specialists

Often required (HMO plans)

2026 plan stability

Guaranteed by federal law — cannot be discontinued

1 in 10 enrollees forced to switch plans for 2026; rural areas hit hardest

Chronic care support

SPARK CCM/APCM: monthly clinical contact, care planning, 24/7 access

Varies by plan; often limited to an annual wellness visit

Remote monitoring

SPARK RPM: blood pressure, glucose, weight — tracked with clinical follow-up

Rarely included; usually a paid add-on if available at all

Dental/vision reality

Not included — but SPARK helps coordinate community resources

Marketed broadly; only 38% of enrollees with the benefit use it annually due to caps

Future Medigap options

Preserved — no MA enrollment history to complicate underwriting. ~87% of FFS carry supplemental coverage; ~43% specifically in Medigap

May trigger medical underwriting if you try to add Medigap later

SPARK Care Value / Patient

~$215 / mo

APCM + BHI + RPM (Pathway B) per qualifying patient — clinically delivered, CMS-funded. This is the care MA advertises as "extra benefits," funded from plan margin.

2026 MA Forced Disenrollment

10% of enrollees

Up from ~1% historical average — tenfold increase in two years driven by insurer exits. Rural beneficiaries: 23% of plan terminations vs. 14% of enrollment. (Johns Hopkins / JAMA, Feb. 2026)

Effective FFS-Majority Counties

10 of 10

6 of 10 FFS-majority on raw CMS data. 74% of MA plans are PPOs — discounting PPOs with no in-county provider, the effective FFS-equivalent share is 10 of 10.

Stage 1 · Market Assessment · Section 1.8

FFS/Medigap SPARK Model vs MA/ACO — The Money

$0 premium doesn't mean $0 cost — it means the cost shows up as copays and coinsurance instead of a monthly bill. Medigap converts uncapped risk into a fixed premium. Here is the actual cost structure of all three paths, line by line.

§ 1.8SPARK Senior Health
Investment Book · 2025–2026

FFS vs. FFS + Medigap vs. $0-Premium MA — Line by Line

Part B premium $202.90/mo is the same for all three paths — the differences start below it

Line item

FFS Only

FFS + Medigap G

MA $0 Premium

Monthly Part B premium

$202.90

Plan premium

$0

~$162–233/mo (GA avg)

$0

Part D drug premium

~$72/mo (GA avg)

Usually bundled $0–variable

Part A hospital deductible

$1,736 — you pay

$0 — Medigap pays

Replaced by MA copay/day

Part B coinsurance (visits)

20% — no cap

$0 after deductible

Fixed copay ($0–$50)

Hospital days 61–90

$434/day — you pay

$0 — Medigap covers

MA per-diem copay (varies)

SNF days 21–100

$217/day — you pay

$0 — Medigap covers

MA per-diem (varies)

Annual OOP maximum

None — uncapped

~$283/yr (Part B deductible only)

$8,000–$8,485 in-network

Illustrative Annual Cost Comparison

Scenario

FFS Only

FFS + Medigap G

FFS + Medigap G w/ PDP

MA $0 Premium

Low-use year

~$2,435

~$4,375–$5,224

~$5,239–$6,088

~$2,435–$3,000

High-use year

$8,000–$12,000+

~$4,660–$5,510

~$5,524–$6,374

Up to $8,000–$8,485

FFS-only carries uncapped risk. Medigap trades a fixed monthly premium for that risk. $0-premium MA trades a $0 premium for a plan-controlled network and a real (if capped) out-of-pocket cliff. Illustrative only.

Medigap Adoption — National & Georgia

US — FFS with Medigap specifically

~42–43%

US — FFS with any supplemental coverage

~87%

Georgia — FFS with Medigap

~32–38%

SPARK 10-county footprint — FFS members w/ standalone PDP

~75%

Georgia's lower Medigap adoption reflects higher MA penetration (48–55%) and the absence of strong guaranteed-issue protections. Rural Appalachian counties — SPARK's footprint — plausibly run above the GA state average. 75% PDP figure derived from CMS State/County PDP Penetration file (July 2026) vs. county FFS pool. (KFF/NAIC 2023, AHIP, CMS 2026)

Stage 1 · Market Assessment · Section 1.8

FFS/Medigap SPARK Model vs MA/ACO — 2026 Market Reality

Insurer exits and forced disenrollments have surged to their highest levels in the program's history. Rural beneficiaries are bearing the brunt. SPARK's FFS model is structurally insulated from this instability.

§ 1.8SPARK Senior Health
Investment Book · 2025–2026

SPARK Service Footprint — Where Beneficiaries Stand Today

CMS MA State/County Penetration files via Connie Health · 2026 data where available · gold = FFS majority

County

MA %

FFS %

Plans / PPO%

Avg OOP Max

Gilmer (E. Ellijay)

44.62%

55.4%

41 / 73% PPO

$7,679

Rabun (Clayton)

46.78%

53.2%

44 / 80% PPO

$8,381

Union (Blairsville)

47.14%

52.9%

42 / 76% PPO

$8,354

Fannin (Blue Ridge)

47.03%

53.0%

43 / 77% PPO

$7,819

Lumpkin (Dahlonega)

48.42%

51.6%

47 / 72% PPO

$8,188

Stephens (Toccoa)

49.68%

50.3%

50 / 68% PPO

$8,084

Gordon (Calhoun)

52.89%

47.1%

26 / 81% PPO

$8,485

Habersham (Cornelia)

56.30%

43.7%

43 / 65% PPO

$8,044

White (Helen)*

57.32%

42.7%

47 / 68% PPO

$6,826

Chattooga (Summerville)

67.20%

32.8%

49 / 74% PPO

$7,740

Gold rows = FFS-majority on raw CMS data. *White County 2026 unconfirmed; 2024 data shown. 315 of 428 plans (74%) are PPOs — discounting PPOs with no in-county provider shifts effective FFS-equivalent to 10 of 10 counties.

MA Is Destabilizing — Especially in Rural Markets

MA forced disenrollment 2026

10%

vs. ~1% historical average — tenfold increase in two years (Johns Hopkins/JAMA, Feb. 2026)

Rural share of 2025 plan exits

23%

vs. 14% of MA enrollment — rural counties disproportionately harmed (KFF, March 2026)

MA enrollment trajectory

Declining for first time in ~20 yrs

From ~50% → ~48% nationally in 2026 — structural tailwind for FFS

Network Reality Check

74% of MA plans across our 10 counties are PPOs — plans that advertise "see any doctor" but offer no guarantee of a contracted local provider in a thin rural market.

CMS explicitly relaxes network adequacy for rural counties: up to 70–95 minute travel times for primary care, 85% (not 90%) compliance threshold, and formal Exception Requests (42 CFR § 422.116).

Net effect: a plan can be marketed as available in a county while all contracted providers sit well outside it. SPARK's counter is structural — our care team is physically in-county by design.

Stage 1 · Market Assessment · Section 1.8

FFS/Medigap SPARK Model vs MA/ACO — SPARK Care Value Stack

Medicare Advantage funds "extra benefits" from CMS payments that also cover overhead and plan margin. Original Medicare pays directly for clinically delivered longitudinal care. SPARK bills two pathways depending on patient complexity — the care MA advertises, delivered as a clinical service.

§ 1.8SPARK Senior Health
Investment Book · 2025–2026

Pathway A — CCM + RPM (Non-Complex Tier)

For patients with 2+ chronic conditions, non-complex — monthly chronic care management + remote monitoring

Service

2026 CMS Code

Est. Revenue

CCM — non-complex (first 20 min/mo)

99490

~$66.30/mo

CCM — add'l time (each 20 min)

99439

~$50.56/mo

RPM — device supply (16+ days data)

99454

~$52/mo

RPM — clinical review (20 min mgmt)

99457

~$52/mo

Combined monthly value

~$171/mo

Pathway B — APCM + BHI + RPM (2+ Conditions)

For patients with 2+ complex chronic conditions — advanced primary care management + behavioral health + remote monitoring

Service

2026 CMS Code

Est. Revenue

APCM — 2+ conditions

G0557

~$53.91/mo

Behavioral Health Integration add-on

G0570

~$57/mo

RPM — device supply (16+ days data)

99454

~$52/mo

RPM — clinical review (20 min mgmt)

99457

~$52/mo

Combined monthly value

~$215/mo

CCM and APCM cannot be billed for the same patient in the same month — SPARK selects whichever fits the patient's clinical picture. Rates reflect 2026 CMS Physician Fee Schedule national non-facility averages; actual payment varies by locality (GPCI). Complex CCM can exceed $144/month for 60+ min/month patients.

The Bottom Line for Members

✓ No network restrictions, no referral requirements, and no risk of a forced plan change if an insurer exits the county

✓ Monthly clinical contact and remote monitoring — not just an annual wellness visit — funded directly by Medicare, not plan overhead

✓ Preserved future Medigap options: no MA enrollment history. ~87% of FFS carry supplemental coverage; ~43% specifically in Medigap

✓ A local care team, physically in your county — "local access" is the model, not a network map exercise

Why This Is an Investor Advantage

Structural moat: SPARK is not competing with MA plans for enrollment — it is the FFS infrastructure those beneficiaries lack. MA instability increases demand for exactly what SPARK provides.

Revenue certainty: CMS billing codes are defined, published, and guaranteed by federal law — no plan contract, no network negotiation, no annual rate reset by an insurer.

Attribution stickiness: Day 1 AWV establishes CMS attribution. CCM/APCM monthly contact reinforces it. Panel churn in FFS primary care is historically low relative to MA enrollment churn.

10% HPSA bonus: All 10 SPARK counties are HPSA-designated — every CMS billing code pays 10% above the national rate from Day 1. MA plans cannot replicate this structural premium.

Sources: KFF Medicare Advantage Enrollment & Plan Landscape briefs (2026); Johns Hopkins Bloomberg School of Public Health / JAMA forced-disenrollment research letter (Feb. 2026); CMS MA State/County Penetration files; 42 CFR § 422.116 (MA network adequacy standards); CMS 2026 Physician Fee Schedule Final Rule; Connie Health county plan data (2025–2026). Figures are illustrative — verify against current CMS Landscape files before external distribution.

Stage 1 · Market Assessment · Summary

Stage 1 Summary & Key Findings

Six chapters of market validation synthesized. The opportunity is real, quantified, and ready to build on. Proceed to Stage 2 — Model Development.

Stage 1SPARK Senior Health · Confidential
Investment Book · 2025–2026

44,376

Confirmed FFS members · 10-county NE Georgia portfolio

~8,800

Target enrolled at 25% penetration · base scenario

$8,400

Annual CMS overspend per unmanaged member · the revenue engine

24%

Rural GA seniors with no PCP · uncontested enrollment opportunity

10 / 10

Counties HPSA-designated · 10% Medicare bonus applies to all 10 clinics

0

Known FFS primary care competitors with CCM/APCM/RPM billing infrastructure in portfolio

§1.1 — National Context

Rural America's physician shortage, hospital collapse, and CMS overspend create a structurally defined gap. Fixed-clinic + transportation primary care with CCM/APCM/RPM billing is the infrastructure solution — timed with CMMI's active innovation mandate and a 10% HPSA bonus from Day 1.

46M rural Americans 149+ closures

§1.3 — NE Georgia Launch Cluster

#10 worst nationally, #1 HPSA score in GA (8.30), NGHS hospital orbit, <4% avg HMO penetration, 44,376 confirmed FFS members. All 10 counties HPSA-designated — 10% Medicare bonus applies across the full portfolio.

HPSA 8.30 #1 GA NGHS orbit

§1.4 — FFS Population Sizing

44,376 confirmed FFS members across 10 counties. 30% Dual/QMB (G0558 tier), 45% chronically ill FFS (CCM), 15% APCM G0557, 8% low-acuity G0556. ~41% RPM-eligible. Blended PMPM ~$239 at full enrollment maturity (base scenario). Transportation model: 1 driver/clinic, van logistics only, care at fixed site.

44,376 FFS ~$239 PMPM

§1.5 — County Selection & Expansion

3-year 10-clinic rollout. Y1 (Seed): Habersham (M1), Lumpkin (M3), Stephens (M5). Y2 (Series A): White, Rabun, Union (M13–M15). Y3 (Series B): Fannin, Gilmer, Gordon, Chattooga (M25–M29). Composite scoring: HPSA score × FFS pool × low HMO × hospital proximity. All 10 counties HPSA-designated. Series B waived if WC ≥ $1M at Y2 end.

Habersham #1 $2.35M Seed

§1.6 — Utilization & Cost

192 ER visits/1K vs 84 national. $17,600 unmanaged vs $9,200 managed = $8,400 delta/member. At 400 members managed: $3.36M/yr CMS savings — the CMMI application threshold. At 8,800 enrolled (full portfolio): ~$79.8M/yr savings. 1.4 PCP visits/yr baseline → 4.0→6.5 target with transport-enabled access.

$3.36M @ 400 members CMMI threshold

§1.8 — FFS/Medigap SPARK Model vs MA/ACO

FFS is the majority in 6 of 10 SPARK counties on raw CMS data — effectively 10 of 10 when PPOs with no in-county provider are discounted. MA forced disenrollment surged to 10% in 2026 (vs. ~1% historical); rural counties bear 23% of plan exits. SPARK's CCM/APCM/RPM value stack (~$171–215/mo) delivers clinically what MA advertises as a plan benefit.

10 of 10 effective FFS ~$215/mo care value

§1.7 — Competitive Landscape

Zero known FFS primary care competitors with CCM/APCM/RPM billing infrastructure in the 10-county portfolio. NGHS hospital system and local PCPs are partners, not competitors. ACOs and MA plan conversion are the primary "watch" threats — mitigated by low NE GA HMO penetration (<4%) and CMS attribution stickiness via Day 1 AWV protocol.

0 direct competitors NGHS = partner

Next Stage

Stage 2 — Model Development

Brand identity · Clinic design (external + interior layout) · Clinical model & care protocols · Staffing model · AI & technology integration

SPARK Senior Health Proprietary & Confidential Stage 2 →