The Charlotte, N.C.-based Premier Inc. has sent a list of recommendations to the Ways and Means Health Subcommittee on how to deliver regulatory relief for healthcare stakeholders.
The recommendations from Premier, on behalf of the 3,900 U.S. hospitals and more than 150,000 other provider organizations in the Premier healthcare alliance, are about “delivering relief from the regulations and mandates that impede innovation, drive up costs, and ultimately stand in the way of delivering better care for Medicare beneficiaries,” the letter to the Congressional committee stated.
Premier noted that a key driver for this set of suggestions is that “Too often in the recent past the Centers for Medicare & Medicaid Services (CMS) has pushed through new programs and initiatives without giving thoughtful consideration to the resources and time needed by providers to implement these programs in an effective way without disrupting the health care provided to beneficiaries.”
Some of the recommendations from Premier, that the organization stated Congress and CMS could assist the hospital community in making the Medicare program more efficient, include:
- CMS should supply sufficient technical information when proposing new payment models to allow stakeholders to realistically evaluate payment impact. Models such as the Bundled Payment for Care Improvement (BPCI) and the Chronic Care for Joint Replacement (CJR) incorporate benchmarking and reconciliation processes that are both complicated and complex. As another example, CMS has released virtually no information on the calculations underpinning the new Medicare Shared Savings Program (MSSP) Track 1+ and how it may differ from the existing tracks.
- CMS should allow participant groups more time to assimilate new models before introducing additional models that involve the same groups. It is understandable that several alternative payment models would be introduced in a short timeframe as the Innovation Center ramped up its activities. However, the continued rapid introduction of episode-based initiatives, each more expansive than its predecessor in scope, in overlapping geographic areas does not support an organized and orderly transition to value-based care delivery.
- Make participation in APMs and Advanced APMs voluntary. “While we applaud CMS for developing new models that meet the Advanced Alternative Payment Model (APM) definition under the Quality Payment Program (QPP), we encourage CMS to develop APMs and Advanced APMs that are voluntary and allow providers sufficient time to put systems in place to monitor the health of populations prior to the models’ implementation,” Premier said.
- Participants in all APMs and Advanced APMs need monthly data, including on substance use, on an ongoing basis to be successful in the program.
- Flexibility in payment rules and legal requirements. Premier strongly encourages policies that that provide additional flexibility to ACOs and that align payment rules in order to provide the most efficient and high quality care to beneficiaries. There are, however, payment rules that run counter to the goals of an ACO. Within an ACO, the goal is to treat the patient in the right setting regardless of payment policies that micromanage care and restrict innovation. As long as the ultimate outcome is high-quality, cost-effective care, the ACOs should be able to direct patients to the appropriate setting without reduced payment.
The entire letter and descriptions of recommendations in full can be downloaded here.