Industry advocates offer checklist to improve value-based payment models

CMS Innovation Center
Greater flexibility and better consumer protections top the wish list of recommendations for groups providing feedback to CMS on how to improve its innovative value-based payment models.

CMS recently requested feedback on its efforts to promote value-based care. Advocacy groups have some concrete recommendations as the agency juggles various stakeholders’ priorities.

CMS Administrator Seema Verma's announcement soliciting feedback on value-based payment models raised alarms among some lawmakers who were concerned the move represented a front for undermining Medicare. Responses offered by the Medicare Rights Center and the Alliance of Community Health Plans (ACHP) have opted to take the agency at its word, offering a mix of general principles and concrete examples intended to ensure innovative payment models do not hurt the experience of Medicare patients.

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“As new models are tested, it is critically important that any changes to Medicare payment do not diminish access to care, care quality or the overall consumer experience with the Medicare system,” warned Julie Carter of the Medicare Rights Center, which introduced a comprehensive proposed checklist (PDF) to ensure new models maintain consumer protections. The report’s findings highlight patient engagement, improved communication and transparency as key areas of focus.

Among its recommendations:

  • Include patients in the design and evaluation of payment models to improve engagement and ensure their perspective does not get lost as providers and plans focus on the cost-cutting side of the value equation.
  • Develop standardized channels and methods of communication to ensure patients receive consistent information both from CMS and from their plans and providers.
  • Improve transparency about use of patient data and patient rights.
  • Provide patient advocacy resources such as independent ombudsmen.
  • Provide full and transparent access to information that can assist patients in making informed choices about their care, including potential conflicts of interest among providers or plans.

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Meanwhile, many of ACHP’s recommendations (PDF) focus on increasing flexibility within plan design, for example:

  • Expand access to care by allowing greater flexibility in the use of telehealth-based services.
  • Add flexibility to audit requirements, particularly by embracing electronic communication channels, to help trim administrative costs.
  • Strengthen the ability of Part D plans to manage prescription drug utilization by allowing midyear drug formulary changes and reducing the number of drugs that are considered “protected classes," among other policy changes.
  • Design and test payment reforms and models of care that reward providers and organizations for integrating medical care and behavioral health services.
  • Evaluate the impact of payment to community-based organizations for services to address social determinants of health.

"We appreciate CMS’ willingness to consider new approaches and models of care by providing regulatory flexibility to health plans and states and engaging in new demonstration projects," the group said.