SPARK Senior Health · Proprietary & Confidential · All Rights Reserved
Market
Assessment
NE Georgia · 10-County Portfolio · 2025–2026
6 Chapters · NE Georgia · 10-County Portfolio · Investment Book 2025–2026
1.1
The National Context
Rural healthcare crisis, CMS cost burden, policy landscape
1.2
NE Georgia as the Launch Cluster
HPSA scores, NGHS hospital orbit, low HMO penetration
1.3
Medicare FFS Population Sizing
~44,376 FFS across 10 counties · Dual-eligible segmentation
1.4
County Selection & Expansion Sequence
Composite scoring, HPSA rankings, 3-year rollout
1.5
Utilization & Unmanaged Cost Baseline
ER rates, readmissions, PCP gap, CMMI savings argument
1.6
Competitive Landscape
FQHCs, hospital systems, ACOs — partner, neutral, or watch
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 — Novitas J-6 MAC
  • ✓ No capitation, no risk-sharing, no plan oversight
  • ✓ CCM/APCM/RPM billed monthly, per-member
  • ✓ ~52K 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 (9,500 members), annualized CMS savings exceed $79M/yr — converting demonstrated outcomes into non-dilutive expansion capital.
Stage 1 · Market Assessment · Section 1.2
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.
§ 1.2SPARK 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 1.3
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 9,500+ enrolled members across 10 clinics.
§ 1.3SPARK 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
~9,500
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 ~$250 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) ~$250
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 1.4
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.
§ 1.4SPARK 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
#CountyCounty SeatFFS PoolHPSALaunchYearRationale
1HabershamCornelia5,066 ✓ HPSAM1 Y1 · SEED Flagship · US-441 corridor · NGMC 4 mi · PECOS anchor
2LumpkinDahlonega3,946 ✓ HPSAM3 Y1 · SEED GA-400/US-19 · NGMC on-campus · 8.1% ACO pen
3StephensToccoa3,554 ✓ HPSAM5 Y1 · SEED 5-county hub · Stephens Co. Hosp 2 mi · Strong TOC
4WhiteCleveland3,766 ✓ HPSAM13 Y2 · SER-A US-129 corridor · contiguous to Lumpkin · 10% Medicare bonus applies
5RabunClayton3,251 ✓ HPSAM13 Y2 · SER-A Upper mountain · 0.8% HMO — near-zero MA competition
6UnionBlairsville5,571 ✓ HPSAM15 Y2 · SER-A Largest FFS pool in Y2 cohort · 0.9% HMO · 10% Medicare bonus applies
7FanninBlue Ridge5,078 ✓ HPSAM25 Y3 · Self 0.6% HMO — cleanest Medicare market in GA
8GilmerEllijay5,460 ✓ HPSAM25 Y3 · Self No FQHC in county · contiguous to Fannin · NW GA cluster
9GordonCalhoun6,107 ✓ HPSAM27 Y3 · Self Largest FFS pool in portfolio · HPSA-designated · 10% Medicare bonus applies
10ChattoogaSummerville2,577 ✓ HPSAM29 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 = ~9,500 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 1.5
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.
§ 1.5SPARK 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
Metric
Rural GA Now
Our Target
National Avg
ER visits / 1K
192
≤ 130
84
30-day readmit %
22%
≤ 16%
15%
PCP visits/yr
1.4
≥ 2.8 (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)
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 (9,500 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 9,500 members (full portfolio maturity)
Stage 1 · Market Assessment · Section 1.6
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.
§ 1.6SPARK 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 · 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
~9,500
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
§1.2 — 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
§1.3 — 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 ~$250 at full enrollment maturity (base scenario). Transportation model: 1 driver/clinic, van logistics only, care at fixed site.
44,376 FFS ~$250 PMPM
§1.4 — 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
§1.5 — 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 9,500 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
§1.6 — 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 →