From international law firm Arnold & Porter LLP comes timely views on current regulatory and legislative topics that weigh on the minds of today’s physicians and health care executives.
In a recently released request for information (RFI), CMS is seeking guidance from clinicians and other stakeholders about the resources and processes that will be necessary to achieve a large-scale transformation of physician practices in support of the “triple aim” of better care and better health at lower costs. Specifically, CMS is asking for information about strategies that could support “the participation of large numbers of providers in a redesigned health care system via the pathway that makes the most sense for their practices.”
The RFI defines “practice transformation” as “a process that results in observable and measurable changes to practice behavior” through core competencies such as engaged leadership and quality improvement, team based “healing relationships,” patient-centered interactions, and systematic efforts to reduce unnecessary testing. The RFI notes that, while the current demonstration programs and other initiatives offered through the Centers for Medicare and Medicaid Innovation (CMMI) may include technical assistance for practice transformation, “many clinician practices need assistance in developing their capacity to successfully participate in (a CMMI) model or other alternative value-based payment model (eg, state or Medicaid models).” The RFI also recognizes that providers “who want to transform their care delivery system must then acquire the data, knowledge and skills that support high value care, and be prepared to make the infrastructure investments in systems, staffing and practice work flows and process redesign necessary to be successful.”
The RFI includes 35 specific questions organized into four categories. Relevant examples include:
- What are the existing sources of national, state and local expertise available to assist with leadership development, clinician engagement and overall transformation? What gaps can CMS help to close to build upon these efforts?
- What should CMS consider if it were to organize a program of technical assistance to support the transformation of clinician practices and to prepare for effective participation in value-based payment? What should CMS consider to ensure local “on-the-ground” support to practices? In such a program, what if any role by the state would you find useful?
- What key areas of practice transformation require attention?
- What policies or standards should CMS consider adopting to ensure that groups of solo, small practices and rural providers have the opportunity to actively participate in practice transformation?
- What practice transformation strategies, resources, and tools are most needed to prepare smaller practices to successfully participate in private and public sector pay for value arrangements?
- Which existing educational and assistance efforts might be examples of “best in class” performance in spreading the tools and resources needed for practice transformation? What evidence and evaluation results support these efforts?
- What are the most significant clinician challenges and lessons learned related to transforming a practice, and what solutions have been successful in addressing these issues?
- What are the operational challenges, lessons learned, and successes in developing an infrastructure to support transformation?
- What challenges, not successfully addressed to date, need to be addressed to achieve desired outcomes in health, health care, and more affordable care?
- What would motivate clinicians to participate in any potential future initiatives relating to practice transformation and value-based purchasing?
- Are there particular program-integrity issues that you think you need to address as you pursue transformation? What are they? What barriers do they pose to successful transformation?
This RFI seems particularly timely in light of the bipartisan, bicameral Sustainable Growth Rate legislation’s proposals to encourage the use of alternative payment models for physicians who assume financial risk and use certified EHR technology. These questions should also help inform CMS’ recent efforts to develop practice standards that must be met in order to receive reimbursement for its new chronic care management codes.
Comments must be submitted here by midnight on April 8 in order to be considered.
Ted Lotchin, JD, MPH, can be reached at Arnold & Porter LLP, 555 12th St. NW, Washington, DC 20004-1206; 202-942-5250; email: Ted.Lotchin@aporter.com