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.

Primary care reform efforts showing progress

Four out of seven regions shared in savings with CMS and nearly 95 percent of all practices met quality of care requirements in the second year of CMS’ Comprehensive Primary Care (CPC) initiative. CPC is a multi-payer program launched by the Center for Medicare and Medicaid Innovation (CMMI) in October 2012 to advance primary care by paying clinicians to deliver accessible, comprehensive, and coordinated care in seven regions across the country. Throughout 2015, CPC generated $57.7 million in gross savings in Medicare Part A and Part B expenditures, which was equivalent to the $58 million paid in care management fees to the practices involved. More than half of the participating CPC practices will also receive a share of over $13 million in earn shared savings. According to CMS, the results reflect the work of 481 practices that served over 376,000 Medicare beneficiaries and more than 2.7 million patients overall in 2015.

Four of the seven regions participating in CPC – the states of Arkansas, Colorado, and Oregon, and the Greater Tulsa region in Oklahoma – realized net savings and will share in those savings with CMS; the savings generated in these four regions covered the net losses in the other three CPC regions. In addition to the Medicare savings, CPC practices had lower than expected hospital admission and readmission rates, as well as favorable performance on patient experience.

Gross savings nearly doubled from the first performance year in 2014; practices in four regions were eligible to receive shared savings, compared to one region in 2014. CMMI’s Comprehensive Primary Care Plus (CPC+) will begin on January 1, 2017, with 14 selected regions.

Quality measures

CMS included electronic clinical quality measures (eCQM) for the first time in Medicare shared savings determinations for CPC. CMS noted that these practices with eCQM also exceeded national benchmarks; the eCQM data are recorded in the electronic health record in the routine course of clinical care, enabling real time quality improvement efforts.

The majority of CPC practices that reported eCQM surpassed the median national performance for 10 out of 11 eCQMs in the measure set, with 97 percent of CPC practices successfully reporting nine eCQMs.

CPC initiative

CPC is the largest test of advanced primary care in U.S. history, exploring the potential of primary care clinicians redesigning practices to deliver better care to patients, as well as supporting physicians’ ability to innovate and deliver care to meet patients’ needs and preferences.