- Thirty-five healthcare industry groups recently banded together to offer the newly-approved Department of Health and Human Services (HHS) Secretary a set of guidelines for CMS Innovation Center (CMMI) and alternative payment model development improvements.
The healthcare coalition, which goes by the Healthcare Leaders for Accountable Innovation in Medicare, contains industry leaders such as the American Medical Group Association, Healthcare Leadership Council and National Association of ACOs. The groups intend to ensure CMMI alternative payment model implementation complies with the center’s original intent, which includes limiting demonstration scope and boosting healthcare transparency.
“Our healthcare system is transitioning, as it should, from fee-for-service to value-based care, and that requires the testing of new ideas to make healthcare more quality-driven, cost-effective, and patient-centered,” Mary R. Grealy, Healthcare Leadership Council President, stated on the organization’s website. “We need a CMMI, but we also need safeguards to ensure that CMMI adheres to its original intent, that it test innovative payment and delivery approaches without harm to those who deliver and receive healthcare.”
To strengthen the CMS innovation arm, the coalition provided HHS Secretary Tom Price with six CMMI principles.
First, the CMMI should ensure that alternative payment models go through “strong scientifically-valid testing” before model expansions. All alternative payment models should include “comprehensive, methodologically sound, transparent evaluation plans and occur via appropriately-scaled, time-limited tests.”
The coalition also pushed for voluntary CMMI alternative payment model participation.
Second, the healthcare industry groups asked CMMI to account for the role Congress plays in developing and approving healthcare reform policies.
“The legislative branch has a responsibility to oversee CMMI and must approve model expansions and related changes to Medicare and Medicaid,” the coalition wrote. “CMMI’s important work in testing new models that improve quality or reduce costs without harming beneficiary access or healthcare outcomes should inform congressional decisions on national health policy.”
CMMI alternative payment model participation and Congressional input into model expansions have been points of contention for some policymakers. Before becoming HHS Secretary, Tom Price partnered with other House representatives to urge CMMI to cease mandatory alternative payment model participation for Medicare providers.
The representatives claimed that CMMI overstepped its legislative authority by requiring Medicare providers in certain regions to partake in alternative payment models, such as the Cardiac Bundled Payment Model and the Comprehensive Care Joint Replacement model.
CMMI leaders also failed to limit alternative payment model testing, gather stakeholder input, develop a transparent implementation process, and obtain Congressional approval for model expansions, the representatives added.
The Healthcare Leaders for Accountable Innovation in Medicare echoed Price’s concerns about mandatory alternative payment models and a lack of Congressional approval for alternative payment model expansions.
Third, the coalition recommended that HHS Secretary Price ensure that the CMMI boost alternative payment model development and implementation transparency. By increasing transparency, the coalition aims to also provide stakeholders with more opportunities for input, enhance CMMI accountability, and protect patients and providers.
As part of transparency improvements, CMMI should work on “developing new models in close consultation with affected stakeholders, maintaining complete transparency in decision-making and program procedures, and fully evaluating data and seeking patient and stakeholder input prior to model expansions.”
Fourth, the federal agency’s innovation arm should increase data sharing for alternative payment model testing information. CMMI should make testing data public and regularly update the data to allow for more alternative payment model evaluations.
Increased CMMI data sharing would also help to align private sector alternative payment model development with the federal agency’s value-based reimbursement push.
Fifth, the coalition called on the CMMI under HHS Secretary Price to improve beneficiary safeguards related to alternative payment model implementation.
“Beneficiaries must not be compelled to participate in a demonstration project and must be adequately educated about the project as well as protected by safeguards to ensure continued access and care quality,” the groups stated.
Lastly, CMMI should increase private sector collaboration when developing alternative payment models. The center could boost private sector collaboration by prioritizing models that foster partnerships between providers, payers, and other private sector organizations.
Working more with the private healthcare sector could also facilitate the value-based reimbursement transition across the healthcare continuum.
CMMI has been recognized as a vehicle for alternative payment model development by CMS leaders in the past, but the center could face elimination or reduced funding under a possible Affordable Care Act repeal.
CMS Deputy Administrator for Innovation & Quality Patrick Conway, MD, stated earlier this year that CMMI efforts helped the federal agency achieve its goal of tying 30 percent of Medicare fee-for-service payments to an alternative payment models months before its end of 2016 target date.
The center will also be key to MACRA implementation success, he added. Through CMMI, federal agency staff are developing Advanced Alternative Payment Models that will qualify for maximum incentive payments under the Quality Payment Program.
While Conway touted CMMI successes in a time of uncertainty for the center, the Healthcare Leaders for Accountable Innovation in Medicare intends to improve the center to ensure alternative payment model implementation benefits all healthcare stakeholders.
“These principles will go a long way toward focusing the important work of CMMI on appropriately-scaled projects that align Medicare payment structures with our patients’ healthcare needs,” said Angus Worthing, MD, a chair at the American College of Rheumatology, one of the groups in the coalition.