Providers call for transparency, balanced risk in future CMS payment models

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Providers have given CMS their views on how to best move its innovation center in a "new direction."

The Centers for Medicare & Medicaid Services has expressed a desire to move its innovation center in a "new direction," and providers are offering their opinions on how to push the agency's payment reforms forward. 

CMS issued a request for information at the end of September and accepted comments on the Center for Medicare & Medicaid Innovation's future through the beginning of this week. 

But critics of the move said it was intended to undermine Medicare. 

The American Hospital Association said in a letter (PDF) that future payment models must be built on a foundation of transparency that allows participants to make informed decisions, and that risk and reward are balanced in a way that encourages providers to take on more risk without being unfair. 

"Our members support the healthcare system moving toward the provision of more accountable, coordinated care and are redesigning delivery systems to increase value and better serve patients," the AHA said. "They believe that programs implemented by CMMI are an important step toward determining the best methods to improve the quality of care while also reducing Medicare expenditures." 

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The AHA also said that payment models must minimize the regulatory burden on providers. CMS Administrator Seema Verma has made easing administrative burdens a central goal and has met with a variety of stakeholders to address the issue. 

Premier Inc. said in its own letter that it backs CMS' "guiding principles" as outlined in its request, which include price transparency, a focus on patient-centered care and a push for greater competition, but said that CMMI must continue to be a leading force in designing payment models. 

"CMMI’s flexibility to test innovative models has afforded the opportunity to test more models, develop rapid cycle learnings and refine models during the testing period, develop cross-continuum and multipayer approaches, provide data directly to providers and implement additional legal waivers than traditional demonstrations," Premier said. 

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The Center for Healthcare Quality & Payment Reform issued a report (PDF) on ways that CMS can improve CMMI's approach to testing and developing payment models. In the report, the group noted that CMMI's current process is overly long and burdensome and the center doesn't develop enough physician-centered models. 

Instead, the report offered four ways that CMS can create and operate more effective payment models: 

  1. Embrace a "bottom-up" approach to payment reform. CMS must participate in alternative payment models that physician groups or hospitals have developed locally, as well, to ensure full multipayer support.
  2. Ensure that it has capacity to support multiple payment models at once. There is no one-size-fits-all for payment reform, according to the report. Plus, the agency must develop models for smaller physician groups.
  3. Use "limited scale testing" to speed up implementation. CMMI's current process means that any number of innovative models will never be tested.
  4. Redesign the process it uses to test and implement new models. This is especially key to applying MACRA changes, according to the report.