19 Nov The Task Force Offers Recommendations to the CMS Innovation Center During Its First Listening Session

The Health Care Transformation Task Force provided written comments and offered verbal remarks during the CMS Innovation Center’s first listening session since the release of the Center’s Strategy Refresh White Paper. The Task Force comments took the form of responses to the three questions posed by the Innovation Center.

Summary of Recommendations

1. What is the greatest obstacle to participating in CMS Innovation Center or other value-based, accountable care model? How do you recommend the CMS Innovation Center alleviate this obstacle?
   • • The Task Force sees three main obstacles to participation: (1) barriers to initial entry, (2) barriers to sustained participation, and (3) barriers to APM expansion.
       1. Barriers to Entry: The Innovation Center should: (1) offer technical assistance to providers focused on preparing to participate in APMs, (2) create new opportunities for early infrastructure investments similar to the AIM model, and 3) design on-ramp models with lower risk levels to ease the transition from fee-for-service.
       2. Barriers to Sustainability: CMMI should focus efforts on developing benchmarking methodologies that support appropriate spending levels on care, limit rebasing, and do not penalize model participants for the savings they achieve for their assigned populations.
       3. Barriers to Expansion: CMMI should develop benchmarking and risk adjustment methodologies that establish reasonable expectations for the cost of providing efficient and high-quality care and that can adjust for historic underinvestment in communities and among specific populations.
2. What else could the CMS Innovation Center do to support clinicians and help them be successful in models?
   • • The CMS Innovation Center can help support clinicians in value-based payment models by designing models that attract participation by multiple payers in an effort to bring greater consistency and uniformity to the providers furnishing value-based care.
     • CMS’s leadership would be welcome in developing and advancing a parsimonious set of quality measures that can be applied consistently to different value-based models and which focus on outcomes over processes.
     • CMS can also support clinicians in value-based models by creating flexibilities around care delivery that promote patient-centeredness and reducing unnecessary administrative burdens. HCTTF has long recommended that the Innovation Center adopt a core set of waivers that can be applied and interpreted consistently for all CMMI models, and then add additional waivers as appropriate for specific models.
3. How can the CMS Innovation Center better incorporate patient needs and goals in models? How should the impacts of value-based care on patients be measured?
   • • The Task Force posits that APMs built upon the foundation of accountable care relationships should align to a core set of principles (outlined in the letter) if they are to leverage payment and delivery reform in a way that centers patients, and prioritizes equity, access, and affordability.

Read the Letter