In a letter to CMS, the ACP voiced its support of the Center for Medicare and Medicaid Innovation’s move towards value-based payment models, but also expressed several significant reservations on the testing approaches for new payment models, as well as their impact on disadvantaged patients.
“There are a number of components of these principles that ACP supports; however, we also have significant concerns about some of the language used in terms of what it will mean for the implementation of the key concepts,” Jacqueline Fincher, MD, MACP, chair of ACP’s Medical Practice and Quality Committee wrote.
“For instance, promoting patient choice and competition is a laudable goal but the current measurement systems and means of sharing the information with consumers are simply not ready to support a rapid implementation of that approach — and therefore we recommend that the Agency proceed with great care to ensure that patients and their families do not experience unintended negative consequences by relying on potentially flawed or unclear data to choose a clinician or type of payment structure,” she added.
ACP offered several recommendations to improve CMS’s approach to new model design. ACP cautioned that CMS not move toward systems that depend substantially on consumer choice based on quality, outcome and cost data too quickly. ACP emphasized that physician and patient participation in payment models should be voluntary.
The college also expressed support of a transparent model design and collaboration among CMS and a wide range of stakeholders, such as specialty societies, frontline clinicians and patients and families. To expand successful models, ACP suggested testing smaller scale models and using 1115A(c) under the ACA authority. ACP also recommended expediting reviews and expansion of the models.
ACP noted its support of CMS taking steps to expand opportunities for clinician participation in Advanced Alternative Payment Models (APM). The college warned CMS that current performance measures, measurement systems and means of sharing performance information with consumers are inadequate.
Furthermore, ACP emphasized that payment models should help patients achieve desired health outcomes, but should not penalize patients that fall short of meeting their health goals, especially those with certain social determinants of health that are known to adversely affect patients’ health, such as low socioeconomic status and lack of access to healthy foods.
ACP also urged CMS to facilitate appropriate interaction between primary care physicians and specialists in the payment models.
“We hope that CMS carefully considers our recommendations on accelerating the development of new and expanded options for Advanced APM participation, while also considering the challenges that exist in moving too quickly toward consumer-driven care and market-based models involving price transparency,” Fincher concluded.
“The College looks forward to continuing to work with CMS to support the transition to innovative value-based care models and the development of performance measures that are truly meaningful to physicians and their patients,” she added. “These new measures can better contribute to improved patient quality and outcomes and reduced costs, ultimately allowing enhanced price transparency for patients, physicians, and payers.”
Disclosure: Healio Internal Medicine was unable to confirm relevant financial disclosures at the time of publication.