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Premier Submits Comments on Future of CMMI

November 15, 2017
by Rajiv Leventhal
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Responding to a Request for Information (RFI) on the future of the Center for Medicare and Medicaid Innovation (CMMI), Charlotte-based Premier said 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 its comments, Premier officials highlighted how critical it is for CMMI to continue to serve as a leader in testing value-based care models, incorporating the successes of past models into new models.

In an op-ed in the Wall Street Journal two months ago, Seema Verma, administrator for the Centers for Medicare & Medicaid Services (CMS), 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.

Congress created the center in 2010 to test new approaches and models to pay for and deliver healthcare. In that op-ed, titled “Medicare and Medicaid Need Innovation,” Verma, who is an appointee of President Donald Trump, referred to CMMI as a “powerful tool” for CMS to improve quality and reduce costs.

Verma additionally announced in that piece that CMS is 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,” she said.

In it comments, Premier called for increased participation in Advanced Alternative Payment Models (APMs) under MACRA (the Medicare Access and CHIP Reauthorization Act). Premier suggested that CMS can increase participation in APMs by:

  • Simplifying and aligning policies that enable the most efficient and high quality care, specifically by providing consistent legal and payment waivers across APMs;
  • Developing models for which a sufficient number of specific quality measures can be identified prospectively, and invest funds in the development of new measures to address gaps;
  • Accounting for social risk factors in the quality measures and risk adjustment applied to any model;
  • Expanding the data made available to APM participants;
  • Providing clear guidance on the attribution, precedence and reconciliation rules applied across both permanent and CMMI models; and
  • Developing a larger strategy for dealing with the potential overlap of different programs.

Premier also encouraged CMS to test new models in a manner that would qualify as Advanced APMs, including:

  • A layered payment model demonstration, which is a provider-driven ACO model that includes primary care capitation as well as inpatient and outpatient bundles within a global capitated amount along with legal waivers that will allow providers to employ tools similar to MA plans.
  • A Critical Access Hospital (CAH) Value-Based Purchasing Program, where CAHs could earn up to a 2 percent bonus on inpatient and outpatient services if they successfully report on and meet quality and patient experience thresholds during the first and second years of the program. If, after three years, it can be demonstrated that the group of CAHs as a whole reduced total Medicare spending for the population they serve, then a share of those savings would generate a pool for incentive payments to be distributed back based on related performance.
  • A new voluntary bundled payment model (i.e. BPCI Advanced), which CMS has signaled is forthcoming. CMS should ensure a voluntary model is available as soon as possible as the current BPCI program expires this coming year and a gap between programs would be difficult for providers and suppliers to navigate, which would diminish the success of the follow-on program. CMS should also test bundled payments for episodes that occur in an outpatient setting.

Last year, close to 200 federal lawmakers sent a letter to Andy Slavitt, then-administrator for the CMS, calling out CMMI for overstepping its authority by proposing mandatory healthcare payment and service delivery models. Part of that group who wrote the letter was Tom Price, M.D., who recently resigned as HHS (Health and Human Services) Secretary.

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