The AAMC Nov. 20 submitted a letter to the Centers for Medicare and Medicaid Services’ (CMS) Center for Medicare and Medicaid Innovation (CMMI) regarding its Request for Information (RFI) titled, “Innovation Center New Direction.” In the RFI, CMMI solicits stakeholder feedback on market-driven health care reforms. Specifically, CMMI is interested in testing new payment models in the following areas:
- Increased participation in advanced alternative payment models (APMs);
- Consumer-directed care and market-based innovation models;
- Physician specialty models;
- Prescription drug models;
- Medicare Advantage (MA) innovation models;
- State-based and local innovation, including Medicaid-focused models;
- Mental and behavioral health models; and
- Program integrity.
The AAMC recommends that CMMI consider the following overarching recommendations when exploring future models:
- Continue Medicare’s role as a leader in value-based care;
- Maintain the Innovation Center’s agility/dynamism with regard to its ability to rapidly respond to stakeholder feedback with appropriate programmatic changes;
- Create more opportunities for providers to participate in advanced APMs through increased flexibility and the introduction of new programs; and
- Include APM participation options designed specifically for academic medical centers (AMCs).
In order to maximize provider flexibility and encourage adoption of APMs, the AAMC recommends that CMMI incorporate successful elements of existing risk-based models into future demonstrations, such as caps on risk and meaningful quality metrics. To facilitate physician participation in advanced APMs, the AAMC recommends thatCMS:
- Enable more eligible clinicians to achieve the qualifying or partial qualifying APM threshold;
- Eliminate the 50 clinician cap on Medical home models qualifying as an advanced APM; and
- Develop a fast-track approval process for physician-focused payment models.
Additionally, the AAMC urges CMS to adopt several recommendations regarding waivers, beneficiary protections, physician specialty models, health equity, Medicare Advantage, and Medicaid models. Specifically, the AAMC recommends that CMMI extend existing Medicare payment waivers to future demonstrations to facilitate provider adoption of payment and delivery system reform.
The association also encourages CMMI to develop and test models that will incentivize health systems’ focus on disparity reduction and to facilitate shared learning opportunities across model participants in state and/or locally based models. Finally, the AAMC discourages CMS from adopting a model that would test full prepayment for cancer treatment, noting that a prepaid cancer model would not only be difficult to administer, but also technically difficult to price. The AAMC remains committed to supporting the implementation efforts of AMCs engaged in alternative payment models.