Some of the top policy groups with a stake in alternative payment models (APMs) are calling for the Centers for Medicare & Medicaid Services to improve transparency around its new Center for Medicare & Medicaid Innovation (CMMI) payment models.
Those groups—which also include the National Association of Accountable Care Organizations (NAACOs), the Association of American Medical Colleges (AAMC) and the Healthcare Transformation Taskforce—say there needs to be a more methodical and public process to releasing and updating payment models.
"As you know, responsibly moving to higher levels of financial risk requires a steady and predictable payment environment. This allows organizations to plan their budgets and care coordination activities and to predict how they will fare under any given model," the groups said in the letter. "Creating a clarity and stability for model design will encourage provider organizations to move to higher levels of risk and reward more quickly."
Clif Gaus, CEO of NAACOs, told FierceHealthcare that CMMI is one of the larger government programs that doesn't have an advisory board or a direct group to provide feedback ahead of payment demonstrations or the launch of new models. The Agency for Healthcare Research and Quality and the National Institutes of Health, for example, do have such advisory groups, he said.
"These models are foisted upon us and I think that’s not a healthy partnership process," Gaus said, "and I think that in part generated our letter."
Gaus said the groups' concerns and the letter are not meant to be criticisms of current CMMI head Adam Boehler, but reflect concerns with the agency that significantly pre-date his time there.
Among their asks in the letter: The groups recommend establishing a process similar to those used for other programs, such as the Medicare Advantage Rate Notice and Call Letter and the State Medicaid Director Letters.
"In these programs, certain updates and policy changes are communicated publicly with some opportunity for stakeholder feedback, but without the formality of notice and comment rulemaking," the letter read. " In contrast, in the current Innovation Center models, changes are often communicated through contract amendments—sometimes in the middle of a performance year."
The groups asked CMMI to refrain from making midyear changes which can "have a significant programmatic or financial impact on model participants."
Boehler, deputy Administrator and director of CMMI, told FierceHealthcare he's read the letter and his department is reviewing it.
"I will say even as it stands, we have so many focus areas for engagement on this stuff," Boehler said. "A good example would be the primary care models. You'll see when we release it, we're going to release it with a whole bunch of physician groups and its because we have constant stakeholder engagement."
Data comes from many different places, he said. "One of the big things, when you're doing these models, is, you're getting data from RFI's, you're getting data from Congress when you're meeting with them, you're getting data from groups," he said. "What I need to look at is specifically that approach versus what we do to have lots of engagement. It's been a huge focus of ours."
Paige Minemyer contributed to this report.