06 Oct Task Force provides comments to CMS regarding proposed Episode Payment Model Program
We believe clinical episode-related payments can promote high-quality, high-value and transparent care for Medicare beneficiaries and encourage coordination among providers. These outcomes can be achieved while ensuring access to care and freedom of choice for Medicare beneficiaries, regardless of the severity of their illnesses. Moreover, we applaud many of the design features in the new proposed models; the Proposed Rule outlines the framework for programs that could become very successful at reducing Medicare spending and improving patient care. Our comments offered in response to the Proposed Rule reflect a desire to refine this important initiative to help promote programmatic success in an efficient and effective manner.
Task Force Response Summary
1. Considerations for EPM and CJR within the Quality Payment Program. We support CMS’s proposal to provide opportunities for willing APM entities to voluntarily assume additional obligations which would help them move their transformation progress forward.
2. Make program design and monitoring data available to all participating providers as soon as is practical. The Task Force appreciates that CMS recognizes the importance of providing the ability for EPM participants to request baseline data prior to the start of the first EPM, as well as monthly claims files thereafter as soon as is practical.
3. Improve claims data quality. The Task Force recommends that CMS endeavor to refine the data processes and support an option for eligible EPM Participants to elect quarterly financial reconciliation.
4. Continue BPCI and implement additional voluntary bundled payment models. The Task Force supports the proposal to implement a new voluntary bundled payment model for CY 2018 where the model(s) would be designed to meet the criteria to be an Advanced APM.
Read the letter for more detailed recommendations.
Letter submitted on October 3, 2016