“What might be in the works over at the Centers for Medicare and Medicaid Innovation (CMMI)? Are there new pilot models actively in development that will be rolled out this year? Many industry stakeholders, including federal lawmakers, are eager to know what the relatively opaque agency has in store,” Associate Editor Heather Landi wrote here in an article on January 11.
“Created under the Obama administration, CMMI is charged with piloting, testing and evaluating alternative payment models (APMs)—such as bundled payment models, for example—with the intent of increasing quality and efficiency, while reducing program expenditures under Medicare, Medicaid and the Children’s Health Insurance Program (CHIP),” she noted. “However, CMMI has been notably quiet in the first two years of the Trump Administration with regards to new payment models. Last January, CMS did launch a new voluntary bundled payment model, Bundled Payments for Care Improvement Advanced, the Administration’s first Advanced APM.”
Landi added that, “In several speeches to industry groups this past fall, Health and Human Services (HHS) Secretary Alex Azar has indicated that the Trump Administration is exploring new voluntary bundled payments, and even revisiting mandatory bundled payments, which represents a strong about-face in the Trump Administration’s policy about bundled payment initiatives. Azar has even hinted that CMMI will get more involved in addressing social needs, such as food insecurity and housing.”
Indeed, in a September 6 speech to a meeting of the Physician-Focused Payment Model Technical Advisory Committee (PTAC) in Washington, D.C., Secretary Azar said, “Of the priorities I have picked for HHS, the most ambitious and furthest reaching is transforming our healthcare system into one that pays for health and wellness rather than sickness and procedures… The outcome we’re aiming for is pretty simple: better healthcare at a lower price. But the question of how we deliver this outcome is much more complicated.”
Azar went on to say that “There has been some progress on some of the tools we need to execute this transformation. We have more alternative payment models, more coordinated care, and more value-based compensation than ever before. But the results we hope for haven’t always materialized. As just one example, we saw in the analysis CMS released at the beginning of August that the burgeoning number of Accountable Care Organizations have not delivered significant savings when all costs and incentives are taken into account.”
Importantly, he added, “[T]he best results we’ve seen have been in ACOs that took on two-sided risk—where providers have real accountability for outcomes. We’ve also seen better results from physician-run ACOs, as opposed to hospitals. Without real accountability, we’re just offering bonuses on top of payments that may be too high already. That’s why we have now proposed to simplify the ACO system into two tracks, requiring them to take on risk sooner. As our CMMI director, Adam Boehler, put it last week, if this means somewhat fewer ACOs, that’s okay with us.”
Remember, PTAC was created by the MACRA law, to help HHS get input and feedback for innovative ideas. As the committee’s website notes, “PTAC was created by The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) which was enacted, in part, to improve how the federal Medicare program pays physicians for the care they provide to Medicare beneficiaries. MACRA authorized the creation of Medicare’s Merit-based Incentive Payment System (MIPS) and additional Medicare Alternative Payment Models (APMs). MACRA also created incentives for physicians to participate in APMs, and it specifically encouraged the development of certain types of APMs referred to as physician-focused payment models (PFPMs).” And, as part of all of that, Congress created PATC. Indeed, PTAC’s website notes, “The Secretary is required by MACRA to review PTAC’s comments and recommendations on submitted proposals and post a detailed response on the Centers for Medicare & Medicaid Services (CMS) website.” So it might well be at one of PTAC’s committee hearings that we’ll hear the inside scoop on what’s coming next.
As Landi noted in her Jan. 11 article, “Many healthcare industry stakeholders who support accelerating the transition to value-based care and payment models are eager for CMMI to develop and roll out new voluntary alternative payment models. And others want to see more transparency in the process. Just this week, two Congressional leaders, U.S. Representative Richard Neal (D-MA), chairman of the House Committee on Ways and Means, and Rep. Kevin Brady (R-Texas), ranking member of the committee, sent a letter to Verma calling for greater transparency from CMMI as it develops new delivery and payment models, noting that its process has ‘historically been opaque to Congress and to stakeholders.’”
Indeed, Reps. Neal and Brady wrote, "Significant policy changes made unilaterally by the executive branch without sufficient transparency could yield unintended negative consequences for beneficiaries and the health care community. We strongly urge the Agency to provide more sunshine in this process."
The challenge here is that even the APMs are heading through some very choppy waters right now. As I noted on January 11, The announcement on Wednesday, January 10 by senior officials at the federal Centers for Medicare & Medicaid Services (CMS) that the agency will require participants in the Medicare Shared Savings Program (MSSP) will be required to submit applications to the new Pathways to Success part of the Medicare Shared Savings Program (MSSP) by February 19, has roiled accountable care organization (ACO) leaders nationwide.”
And I quoted extensively a press release from the Washington, D.C.-based National Association of ACOs (NAACOS) that criticized CMS for the timeframe involved, following the issuance of the final rule on December 19. In its Wednesday press release, NAACOS stated that “The Centers for Medicare & Medicaid Services (CMS) late Wednesday announced applications to participate in the new Pathways to Success accountable care organization (ACO) program will be due February 19, two months after the agency published a nearly 267-page rule overhauling the Medicare Shared Savings Program. In response, the National Association of ACOs (NAACOS) is calling on CMS to give ACOs till later in March to understand the complex changes and determine participation options with affiliated doctors, hospitals, and other providers before committing to high-stakes decisions.” And the association quoted its president and CEO, Clif Gaus, Sc.D., as stating that “ACOs barely have time to understand the new rules, and organizing an application is very complicated and for some it is now a high-risk decision. There are too many difficult decisions to rush.”
So we have Secretary Azar stating on the record back in September that it’s OK with him if fewer patient care organizations participate in the MSSP program, and then on December 19, CMS announced that it was setting the deadline for the submission of applications to the new Pathways to Success program for February 19. Well, that move will almost certainly cause some ACO leaders to drop out of MSSP for now; indeed, in that same article, I quoted Jennifer Moore, a NAACOS board member and chief operating officer at MaineHealth ACO in Portland, Maine, as stating that her ACO would probably have to retreat to upside-only participation, simply because of the unreasonable deadline set for submission of applications for 2019 participation in two-sided risk.
So—does CMS have ideas for new voluntary APMs that are being developed now? And, very importantly, how appealing might those ideas be to providers? Here’s what’s clear: with MSSP participation already imperiled because of what providers see as unreasonable timelines in submitting applications for participation in two-sided risk, any new voluntary programs are absolutely going to have to be seen by provider leaders as having at least a moderate level of appeal—at the strategic level, programmatic level, and practical level—in order to attract any participation.
Because honestly, the rhetoric and mixed messages coming out of HHS and CMS right now are meeting with confusion, bewilderment, and frustration on the part of provider leaders nationwide. As I’ve noted in past commentaries, HHS and CMS leaders are caught in a complex policy web, in that they represent a Republican administration whose mantra has been that markets and consumers can help to drive change; yet the practical reality, as they know, is that, without using exceptionally focused, even pointed, strategies to gain participation, any voluntary programs that senior federal healthcare policy officials develop, will crash against a shoal of hard defeat in the face of provider reluctance to participate.
CMMI is a unique organization; created under the ACA to be the Medicare and Medicaid programs’ innovation test bed, it is now caught in a vise between free-market-tinged ideology coming from the White House, and the understanding, among senior HHS and CMS officials, that experimental APMs are going to be needed to be created and adopted, quickly, in order to begin to make a dent in the accelerating healthcare inflation trajectory that continues to bedevil the U.S. healthcare system. What’s more, CMMI Director Adam Boehler appears to be talented and thoughtful; now certainly would be a great time for him to be given the freedom and scope to create meaningful new programs that will appeal to the industry.
And, in the end, as political commentators are fond of saying, in a variety of different contexts, hope is not a strategy. Let’s hope we see CMMI developing appealing APMs that provider leaders can really be enthusiastic about participating in. It’s definitely time.