CMS seeks feedback on ‘new direction’ for Innovation Center

The Center for Medicare and Medicaid Innovation (CMMI) is seeking feedback on a potential “new direction” to promote patient-centered care and test market-driven reforms that empower beneficiaries as consumers, provide price transparency, and increase choices and competition. To be considered, comments on the informal Request for Information must be submitted online or through email by November 20, 2017.

CMMI develops new payment and service delivery models in accordance with the requirements of Sec. 1115A of the Social Security Act, as added by Sec. 3021 of the Patient Protection and Affordable Care Act (ACA) (P.L. 111-148), in an effort to reduce program expenditures while preserving or enhancing the quality of care furnished to individuals. However, CMMI has recently come under fire; HHS Secretary Tom Price criticized CMMI for dictating the type of care physicians are to provide for patients. In August 2017, CMS proposed to eliminate the Episode Payment Models and Cardiac Rehabilitation incentive payment model and revise aspects of the Comprehensive Care for Joint Replacement model (see Out with the old models, CJR model gets revamped, August 16, 2017).

In the Request for Information, CMMI sought feedback on testing models in eight areas: (1) increased participation in Advanced Alternative Payment Models (APMs); (2) consumer-directed care and market-based innovation models, which could empower beneficiaries to make choices from among competitors in a market-driven health system; (3) physician specialty models; (4) new models for prescription drug payment, in both Medicare Part B and Part D and Medicaid, that incentivize better health outcomes for beneficiaries at lower costs and align payments with value; (5) Medicare Advantage (MA) innovation models; (6) state-based and local innovation, including Medicaid-focused models; (7) potential models focused on behavioral health, including opioids, substance use disorder, dementia, and improving mental health provider participation in Medicare, Medicaid, and CHIP; and (8) program integrity.

In an op-ed piece, CMS Administrator Seema Verma called CMMI a “powerful tool” for improving quality and reducing costs. House Ways and Means Committee Chairman Kevin Brady (R-Tex) lauded CMMI’s issuance and said that the Obama Administration at times used the Innovation Center’s authority “in a top-down manner through mandatory, national ideas that received little to no input from those actually providing care to patients,” resulting in bipartisan Congressional concern for patients and stakeholders.

Wait! Physicians are not ready for the QPP

Physicians expressed concern over their knowledge of and preparedness for Medicare’s Quality Payment Program (QPP) in a recent American Medical Association (AMA) and KPMG consulting survey. Only 10 percent of responding physicians expressed feeling deeply knowledgeable about the Medicare Access and Chip Reauthorization Act (MACRA) (P.L. 114-10) or the QPP and 90 percent of respondents indicated that they find the requirements of MACRA’s merit based incentive payment system (MIPS) to be slightly or very burdensome.

QPP

MACRA created the QPP, which, in January 2017, began marking the quality performance of physicians. In 2019, the program will make adjustments to physician payments under one of two tracks: (1) MIPS or (2) a 5 percent lump sum bonus payment if the physician has a threshold percentage of patients or revenue in an advanced alternative payment model (Advanced APM). Because little is known about physician preparation under the program, the AMA and KPMG conducted a survey to gauge physician readiness and knowledge. The survey of 1000 physicians was conducted between April 25 and May 1, 2017, prior to proposed updates to the QPP program released on June 30, 2017 (see Halfway through QPP ‘transition year,’ CMS proposes substantial changes, June 30, 2017).

Findings 

Only 51 percent of physicians expressed feeling somewhat knowledgeable about MACRA and the QPP. Seven in 10 respondents have begun preparation for QPP in 2017, however, of those respondents preparing for MIPS in 2018, only 65 percent reported feeling prepared. The vast majority of respondents—90 percent—indicated that they found MIPS’ requirements burdensome. The cause of that burden, for most respondents, was the time and cost associated with reporting. Physicians expressed specific concerns regarding the unknown financial ramifications of the program, with only 8 percent of respondents indicating they were very prepared for long-term financial success under the program.

Impact

The AMA and KPMG survey concluded that some impacts—time and complexity of reporting—impact physicians regardless of practice size, specialty, or previous reporting experience. Additionally, physicians across practice areas agree that long-term financial impacts remain uncertain and that the program would benefit from more APMs.

CPC+ Round 2 taking applications from Louisiana, Nebraska, North Dakota, and Buffalo NY practices

The second round of regions for participation in the Comprehensive Primary Care Plus (CPC+) model, an Advanced Alternative Payment Model (Advanced APM) has been announced by CMS, which is seeking eligible practices in three statewide regions—Louisiana, Nebraska, and North Dakota—and in the Greater Buffalo Region (Erie and Niagara Counties), New York. CPC+ Round 2 will accept applications beginning May 18 through July 13, 2017; accepted practices will be part of an innovative payment structure that rewards value and quality for primary care practices that improve quality, access, and efficiency. The four regions were chosen based on payer alignment and market density.

CPC+ Round 2 is smaller than Round 1, which included 14 regions (see More clinicians able to join Next Generation ACOs, CPC+ for 2018, December 16, 2016), and chosen practices will participate from 2018 through 2022. Practices located in Round 1 regions are not eligible to participate in Round 2, even if they applied for Round 1 and were not accepted or did not apply for Round 1. As part of the announcement for Round 2, CMS also provisionally selected five payer partners to provide additional support in certain Round 1 regions.

CPC+ was developed by the CMS Innovation Center, which was established by section 3021 of the Patient Protection and Affordable Care Act (ACA) (P.L. 111-148). As an Advanced APM, the program is part of the Quality Payment Program (QPP), which is designed to reform Medicare payments to physicians as part of CMS’ implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) (P.L. 114-10).