18 Nov The Task Force Offers Recommendations to the Medicare Payment Advisory Commission for Advancing the Adoption of Alternative Payment Models
The Health Care Transformation Task Force sent a comment letter to MedPAC building off of the commissioners June 2021 report recommending that CMS streamline its Alternative Payment Model (APM) portfolio. In this letter, the Task Force expresses support for many of the MedPAC recommendations and offers perspectives on and recommendations for ways that MedPAC, Congress, and CMS can further advance the adoption of APMs.
Task Force Comment Summary
- HCTTF urges MedPAC to continue to highlight the range of benefits that transitioning away from FFS payments in favor of APMs can have for health care stakeholders and the system itself. In its June 2021 report, MedPAC discusses the potential benefits of APMs beyond gross spending and quality improvements. Properly designed APMs can address many of the challenges that make the health care system frustrating for both providers and patients. In addition to the benefits highlighted in the report, the Task Force also notes that APMs can incentivize better care coordination, enable more flexible care delivery via telehealth and care teams, free up resources to evaluate and address social needs, and encourage more proactive provider engagement with patients.
- Maintaining momentum for APM adoption. The Task Force highlights the importance of MARCA and the Advanced APM bonus as a driver of provider interest in transitioning away from fee-for-service and adopting APMs. We encourage MedPAC to join HCTTF and many other organizations in recommending Congress extend the current AAPM bonuses until 2030.
- Improving the APM portfolio. The Task Force expresses support for many of the MedPAC recommendations for streamlining the APM portfolio. In addition to these recommendations the task force highlights the importance of CMS establishing a clear vision for the future of payment reform that communicates the limited future of fee-for-service payments and offers detailed guidance regarding how it intends to operationalize the objectives spelled out in the CMMI Strategic Refresh white paper at the level of individual models.
- MedPAC Research Priorities. HCTTF notes the important role that MedPAC plays in providing well researched recommendations for improving Medicare. To this end the letter identifies several research topics that the Task Force believes would advance the state of APMs. These include:
- Approaches for using CMS payment reforms to advance equity such as improving demographic data collection via new or existing sources to support equity measurement, recommendations for integrating equity into existing quality and performance scoring, considerations for evaluating the benefits of equity focused models (including appropriate timelines for impact measurement), and how the benefit of reducing disparities should be accounted for in the CMMI model certification process.
- Strategies for streamlining APMs and driving accountable care relationships including 1) identifying how CMS can better support provider efforts to align beneficiaries (including expanding access to data) and 2) outlining approaches for creating complementary or nested population health and episodic models of care that could be applied as reforms to existing and future CMS model efforts.
- Approaches for expanding APM adoption such as the need for infrastructure investments to support provider adoption of APMs, opportunities to align investments across payers to reduce duplication of effort and complexity, and aspects of model design that inhibit broader uptake (e.g., minimum beneficiary requirements in low density rural areas, benchmarking methodologies that reflect historical spend rather than needed care in underserved communities).
- Pathways for improving affordability and patient engagement including opportunities for testing expanded cost sharing/co-pay waivers and other affordability and engagement enhancements for patients.