22 May HCTTF Recommendations for Design of Mandatory Models
The Health Care Transformation Task Force (HCTTF or Task Force) shared feedback with CMS on the development of mandatory value-based payment models. As CMS develops future mandatory models, we believe this feedback will be useful in the design and implementation of mandatory models that will effectively drive down costs and improve quality of care.
The Task Force has regularly provided CMS with constructive feedback about mandatory models, including the Comprehensive Care for Joint Replacement model and the proposed Episode Payment Models for cardiac and orthopedic services. HCTTF presents the following recommendations for CMS to consider in future development and implementation of mandatory value-based payment models to support participants in achieving the intended outcomes of lowering costs and improving quality of care.
Task Force Letter Summary
- Design considerations for mandatory models. HCTTF urges CMS to include stakeholders in the design of mandatory models in a significant and consistent way. Private sector clinical experts, consumers, patients, purchasers, and multi-stakeholder groups like the Task Force are well-positioned to weigh in on model development methodology before participation is mandated. We believe simplicity and transparency are critical to the success of APMs because providers’ focus should be on improving care, not trying to parse complex methodologies.
- Additional advanced notice. The Task Force recommends that CMS prioritize providing participants and the public additional advanced notice and information for mandatory models in order to engage stakeholders in model development and ensure that providers have adequate time to prepare for the successful implementation of a mandatory model.
- Research overlap implications. The Task Force has previously provided feedback to CMS on the importance of considering model overlap and synchronization. CMS should provide APM participants adequate flexibility to manage model overlap based on their unique market situation in a way that encourages greater synergy and ultimately drives better outcomes for patients.
Letter Submitted on May 22nd, 2019