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Healthcare providers call for greater clarity and stability from CMMI

CMS should eliminate mandatory mid-year changes and providers should have more opportunity to give feedback, groups tell Seema Verma, Adam Boehler.

The Center for Medicare and Medicaid Innovation should adapt its existing approach for developing, releasing and updating its value-based payment models, according to a group of nine healthcare organizations.

The group is calling on CMMI to implement a more public process that would allow stakeholders to comment on all payment model design elements before finalizing a particular model. The Innovation Center should also make and communicate model changes clearly and publicly--and not in the middle of a performance year--according to a letter sent by the group to CMS Administrator Seema Verma and Innovation Center Director Adam Boehler.

The reason for the proposed changes: Providers require more clarity and stability in model design to encourage greater participation in alternative payment models and the move to higher levels of risk and reward.

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"Accountable care organizations have shown they're committed to new care models, but they need more information on what the future holds if they're expected to fully embrace the Innovation Center's work," said Clif Gaus, president and CEO of the National Association of Accountable Care Organizations, one of the nine groups that signed the letter.

The letter was also signed by the American Medical Group Association, Association of American Medical Colleges, Health Care Transformation Task Force, Medical Group Management Association, National Coalition on Health Care, Next Generation ACO Coalition, Patient-Centered Primary Care Collaborative, and Premier.


The Innovation Center has been a driving force behind many value-based initiatives, such as bundled payment models and accountable care organizations, that base payments on health outcomes and cost of care.

Currently, CMMI often communicates changes to its models through contract amendments that sometimes occur in the middle of a performance year. That approach, the group believes, creates uncertainty that hurts providers' ability to plan their budgets and care coordination activities as well as predict how they will fare under any given model.

To remedy this situation, the group recommends that the Innovation Center establish a process similar to the one used for the Medicare Advantage rate notice: Certain policy updates would be communicated publicly with some opportunity for stakeholder feedback, but without the formal notice-and-comment rulemaking.

"Public communication of model design elements and eliminating mandatory mid-year changes would improve providers' ability to evaluate and compare options while still allowing the Innovation Center to be nimble and flexible," according to the letter. "Affording stakeholders an opportunity to provide feedback will strengthen the model portfolio over the long term and create stability and predictability that supports moving away from fee-for-service and fosters the movement to higher levels of risk and reward."


The letter echoes a recent call from Congress for greater clarity from CMS about its decision-making. In January, House Ways and Means Committee leaders Richard Neal, a Democrat from Massachusetts and Kevin Brady, a Republican from Texas, urged CMS to increase transparency in the Innovation Center's work, and provide greater opportunity for public input as models are developed. The two Congressmen pointed out that the CMMI development process has "historically been opaque to Congress and to stakeholders" and warned against the negative potential consequences if CMS were to "bypass Congress and the public to rewrite Medicare law."


"There is a wealth of expertise from those on the front lines of healthcare delivery and payment transformation--knowledge that should be solicited throughout a more public process of developing and updating models," Gaus said.

Mark Klimek is an independent writer and editor with 20 years' experience covering financial issues, healthcare and more.