The Task Force Offers Recommendations to the CMS Innovation Center in Response to its First Beneficiary Engagement Listening Session

The Health Care Transformation Task Force provided written comments to the CMS Innovation Center in response to its February 9 Listening Session “Incorporating Beneficiary Perspectives into Model Testing, Implementation, and Evaluation”. The Task Force comments took the form of responses to the three questions posed by the Innovation Center.


  1. To what extent are beneficiaries aware of the Innovation Center, its priorities, and role in testing ways to improve care for people with Medicare and Medicaid?

The statement describes a number of challenges related to beneficiaries’ understanding of CMMI, and of the alternative payment model landscape.  To address these challenges the Task Force strongly supports: (1) CMS providing beneficiaries with information and education – in an easy-to-read format offered in a variety of languages – to ensure they understand what programs and models their providers are participating in, and (2) CMS establishing an APM Ombudsman program. The combination of these two activities will allow beneficiaries to understand the APM landscape, learn about specific models that are relevant to their conditions and their care experiences, and have a resource for asking questions and raising concerns when appropriate.

  1. How can CMMI successfully engage patients and beneficiaries to inform future model development, implementation, and evaluation?

The Task Force includes a number of recommendations, including 1) invest in training and education to ensure that there is a deeper and broader bench of diverse patients and beneficiaries that can be called upon to provide input on a timely basis, and that these individuals have the knowledge they need to provide useful feedback and input; 2) establish a continuous feedback loop process with beneficiaries engaged in providing feedback, so they are aware of how their input will be used in decision making; 3) invest in building meaningful Patient-Family Advisory Councils (PFACs) to encourage engagement that addresses payment and care delivery as a core element of all future models; 4) inform beneficiaries about how different APMs measure clinical quality, so they can better understand to what standards their providers are being held accountable; 5) make resources available in multiple languages; and 6) partner with community-based organizations that have experience and expertise with communicating complex issues to consumers and patients and have built strong relationships with community members.

  1. How can CMMI best identify beneficiaries’ priorities and needs?

The Task Force offers CMMI the following recommendations for identifying beneficiaries priorities and needs: 1) partner with community-based organizations, as well as with community development divisions within health care systems, to understand the needs of various patient populations; 2)  establish and regularly convene a governance body that is comprised of a majority of beneficiaries, and recruits and engages beneficiaries and family/caregivers representing a community’s diversity of language, race, ethnicity, socio-economic status, and other demographic variables; 3) acknowledge the historically unequal power dynamics between patients and other health care stakeholders and design the governance body and any other feedback processes to ensure that beneficiaries are able to provide feedback in a way that reflects the importance of the patient; 4) provide equal respect and weight to beneficiary and patient voices as is given to payer and provider voices; and 5) incorporate measures of dignity, trust, and respect in APM performance metrics.


Read the Statement