15 Apr HCTTF Provides Feedback on CMS Waivers
As CMS considers the design of future advanced risk models, the Health Care Transformation Task Force provided feedback on the existing set of waivers available to Center for Medicare and Medicaid Innovation model participants to inform an approach that will lead to meaningful, consistent, and widely-used waivers to promote improved care coordination and outcomes.
Task Force members have deep experience operating value-based payment models in Medicare as well as commercial lines of business. Our members have extensively discussed their experience with waivers in the context of CMS payment models, including the Medicare Shared Savings Program (MSSP), Next Generation ACO model, and Bundled Payments for Care Improvement (BPCI) Advanced. This letter summarizes our members’ feedback and recommendations for waivers and is organized into three categories: 1) general waiver feedback, 2) comments on specific waivers, and 3) ideas for new waivers to improve APMs.
Task Force Letter Summary
- General waiver feedback. Task Force members identified general challenges with existing waivers and recommend improvements, which fall into four areas broadly applicable to all waivers: A) waiver design, B) waiver guidance and feedback, C) uniformity of waivers across models, and D) opportunities for direct model participant connections.
- Comments on specific waivers. Task Force members provided examples where waivers have supported the objectives of APMs and areas for improving existing waivers through clarified guidance and streamlined operations.
- New waiver ideas to improve APMs. Task Force members identified three areas where additional waivers would improve the ability of APM model participants to improve quality and control costs.
Letter submitted on April 15th, 2019