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In Response to Public Comments on CMMI, CMS will Consider Direct Provider Contracting Model

April 24, 2018
by Rajiv Leventhal
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CMS is issuing a follow-up RFI to garner feedback on a potential direct provider contracting model

The Centers for Medicare & Medicaid Services (CMS) has released the comments submitted by healthcare stakeholders in response to the CMS Innovation Center’s new direction request for information (RFI), while also announcing that the agency is considering a direct provider contracting model as a result of the feedback that was received.   

For background, Congress created the Center for Medicare and Medicaid Innovation (CMMI) in 2010 to test new approaches and models to pay for and deliver healthcare. In an op-ed in the Wall Street Journal last September, CMS Administrator Seema Verma said the Trump Administration plans to lead CMMI “in a new direction” to give providers more flexibility with new payment models and to increase healthcare competition. Verma said that CMS would be issuing a request for information to collect ideas on the path forward. “We will move away from the assumption that Washington can engineer a more efficient healthcare system from afar—that we should specify the processes healthcare provider are required to follow,” Verma wrote at the time.

CMS recently said that the agency received more than 1,000 responses to the RFI from a wide variety of individuals and organizations located across the country, including medical societies and associations, health systems, physician groups, and private businesses. Since the RFI comment period closed last November, CMS has been reviewing the responses, “which provided valuable insight on the potential to improve existing models as well as ideas for transformative new models that aim to empower patients with more choices and better health outcomes,” CMS officials said.

What’s noteworthy in CMS’ announcement is that in response to the comments that were received on the RFI, the agency also said that it would be taking a next step to develop a potential model in direct provider contracting (DPC). According to CMS, “A direct provider contract model would allow providers to take further accountability for the cost and quality of a designated population in order to drive better beneficiary outcomes. Such a model would have the potential to enhance the doctor-patient relationship by eliminating administrative burden for clinicians and providing increased flexibility to provide the high-quality care that is most appropriate for their patients, thus improving quality while reducing expenditures.”

As part of its process to gain further insight from the public in this area and ask more focused questions, CMS is issuing a follow-up RFI on the DPC model through May 25.

In the RFI on the DPC model, CMS said that it is aware of a wide range of payment arrangements that involve aspects of “direct provider contracting,” from the existing ACO (accountable care organization) initiatives and CPC+ Model test to capitation arrangements between primary care providers and commercial insurers or Medicare Advantage plans, to arrangements in the private sector where, for example, patients contract directly with physicians and group practices.

Given this range of activities, the agency wrote, “a DPC model (or models) could be tested in an iterative manner with additional options added over time. For purposes of beginning a DPC model test, CMS could contract directly with participating practices, such as primary care practices or larger multi-specialty groups, to establish the practice as the main source of care for services ranging from solely primary care to a wide range of professional services for beneficiaries that voluntarily elect to enroll with the practice.”

Moreover, regarding the CMMI “new direction RFI,” some stakeholder comments were made public late last year, including from Premier, which said that the center should take to “promote patient-centered care and test market-driven reforms that empower beneficiaries as consumers, provide price transparency, increase choices and competition to drive quality, reduce costs, and improve outcomes.” In it comments, Premier also called for increased participation in Advanced Alternative Payment Models (APMs) under MACRA (the Medicare Access and CHIP Reauthorization Act.

Other comments from the EHR Association called for the harmonization of the technology requirements of new payment models with the requirements related to certified EHR technology (CEHRT) already incorporated into other programs, such as advanced APMs and the Merit-Based Incentive Payment System (MIPS). The American Hospital Association (AHA), meanwhile, specifically mentioned its desire for the timely availability of data, while the American Medical Informatics Association (AMIA) recommended that CMS look for ways to provide “innovation support” to grantees, while also leveraging new models and pilots to further promote and optimize the use of informatics tools and capabilities for improved patient care.

According to CMS officials, in totality, the responses focused on a number of areas related to enhancing quality of care for beneficiaries and decreasing unnecessary cost, such as increased physician accountability for patient outcomes, improved patient choice and transparency, realigned incentives for the benefit of the patient, and a focus on chronically ill patients. In addition to the themes that emerged around the RFI’s guiding principles and eight model focus areas, the comments received in response to the RFI also reflected broad support for reducing burdensome requirements and unnecessary regulations.

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