Stakeholder Coalition Urges Verma to Prioritize Advanced Payment Model Participation at Innovation Center

Washington, DC – In a letter sent Friday, the National Coalition on Health Care (NCHC) called on Center for Medicare and Medicaid Services (CMS) Administrator Seema Verma to make broader participation in advanced payment models for physicians, nurses, and clinicians the central focus of the Innovation Center’s efforts to improve quality and curb costs.

“Administrator Verma has the opportunity to move the needle on outcomes by taking the Innovation Center’s flagship payment initiatives to the next level, driving constructive innovation in Medicare Advantage, and listening to consumers and their advocates. NCHC is ready and willing to help move that effort forward,” said John Rother, NCHC’s President and CEO.

In its submission, NCHC made several recommendations aimed at broadening clinicians’ opportunities to participate in the Advanced Alternative Payment Model track that was established by the Medicare Access and CHIP Reauthorization Program Act of 2015 while maintaining those models’ standards. The recommendations were offered in response to an Innovation Center New Direction Request for Information (RFI) announced by CMS on September 20.

NCHC’s letter can be found below, and the detailed comments can be found here:

Dear Administrator Verma:

NCHC is a nonpartisan, nonprofit organization representing more than 80 participating organizations, including medical societies, businesses, unions, health care providers, faith-based associations, pension and health funds, insurers, and groups representing consumers, patients, women, minorities, and persons with disabilities. The Coalition is committed to advancing – through research and analysis, education, outreach, and informed advocacy – an affordable, high-value health care system for patients and consumers, payers, employers, and taxpayers.

We deeply appreciate your decision to offer this Request for Information on the future of the CMS Innovation Center and the opportunity to offer our response.

Since the middle of the last century, America’s health care costs have been driven upward by a fee-for-service reimbursement system that rewards quantity and complexity of services—not positive patient outcomes. Yet after two decades of bipartisan leadership across changes of Administration and Congressional control, federal policy has begun to pursue a more value-based path. In recent years, leading purchasers, plans, and providers, as well as forward-thinking state governments, have increasingly embraced innovative new models of health care delivery and payment.

Unfortunately, NCHC’s provider, clinician, payer, and employer members are now reporting a slowing of value-based contracting, which they attribute to remaining uncertainty about the future of alternative payment models in the current policy environment.

Therefore, the manner and speed with which you employ the Innovation Center’s unique authorities is of particular importance. Actions taken and signals sent now could well determine whether the transition advances at a pace and scale sufficient to enhance affordability or whether most patients and clinicians remain mired in a costly fee-for-service reimbursement system.

For this reason, the National Coalition on Health Care is especially eager to work with you to maximize the Innovation Center’s impact. Our primary recommendation is that you make broadening opportunities for participation in robust Advanced Alternative Payment Models the central goal of the Innovation Center. Our detailed comments are appended, but the rest of our recommendations are summarized below:

• Continue to test and evolve the Innovation Center’s leading models in traditional Medicare. This requires expanding participation opportunities in proven population-based models as well as making the new voluntary bundled payment model available nationwide, on a voluntary basis, during the 2018 performance year. Additionally, to maximize impact on cost and quality, NCHC strongly supports providing advanced organizations the option of assuming full performance risk either for overall spending or primary care services.
• Pursue broader testing of innovative payment models in Medicare Part C. Specifically, we applaud CMS’ decision to grant credit for MA AAPM participation toward MACRA’s participation thresholds and urge CMS to swiftly implement the planned demonstration. Additionally, NCHC supports the testing of a Community-Based Institutional Special Needs Plan (CBI-SNP) Model that uses targeted home- and community-based services to prevent institutional stays among Medicare-only beneficiaries.
• Engage consumer and patient voices in the development and implementation of new models. Engagement of beneficiaries and their advocates is particularly important to the sustainability and impact of payment and delivery reform. As the Agency proceeds, we call for mechanisms to ensure beneficiaries and their advocates are involved in the development, implementation, and evaluation of Innovation Center models.

By aligning federal policy with the most innovative private sector and state payment reform initiatives, your leadership and the work of the Innovation Center can substantially advance the movement toward value. We look forward to working with you toward that end. Please do not hesitate to contact me at [email protected] or NCHC’s Policy Director, Larry McNeely, at [email protected].

Yours truly,

John Rother
President and CEO

***PLEASE CLICK HERE TO SEE THE DETAILED COMMENTS SUBMITTED BY NCHC.