Friday, April 27, 2018

CMS Releases Public Comments on CMMI Reform; May Launch "Direct Contracting" Initiative

Several important news items from the Center for Innovation (CMMI) at CMS.

The Request for Help in Innovation Last Fall

Last fall, with an Op Ed in the Wall Street Journal and a public request for information, CMMI asked for help in rebooting and redirecting its potentially quite powerful Center for Innovation.  Under ACA law, the CMMI can launch pilot projects at nearly any scale (local, national) and waive Medicare law for the purpose of these projects.   For links and comments on the September 2017 initiative, see my blog here.  For selected follow up available in November 2017, here.   This effort is branded the CMMI New Directions program.

Public Comments Now Released

In April 2018, CMS releases the public comments both those provided inside an online form (text boxes) and open-format PDF written comments.  See the toward the bottom of this web page, "Public comments...are available below."  Here.   There were over 1000 comments - press release on the release of public comments, here.

Note that the document-format public comments are released by CMS as one gigantic 284 MB consolidated PDF.  Don't try to open on your iPhone.  It's a scary 4,643 pages.  (My comment is p. 1409-1412).[*]

Direct Contracting Models Considered

Also in April 2018, CMS released a new and more targeted Request for Information, asking whether CMMI should roll out demonstration programs focused on Direct Contracting with providers.  (For example, this could be capitation of primary care.... the "medical home" on steroids.)   CMS notes its proposal is similarly to what is now available from some medical practices by contracting with patients for "direct primary care" or DPC.

See a summary at Healthcare Dive here.   See a follow-up article at Medscape, here. See the CMS webpage here.   CMS is taking public comments for a month, until May 25, 2018.   See a nine page CMS PDF about the topic here

Direct Primary Care

For Google News on Direct Primary Care, here.   For articles on PubMed, here.

For support from the Heritage Foundation, here.  For a representative local news article, here.  For a current update on Healthcare Law Blog, here.



Last fall, I made a four-page comment on CMMI's direction.  Being a strategy consultant, I focused on three fundamentals that CMMI needed to resolve to be efficient and effective in the roll-out of any CMMI program.

First, CMMI needs to address that its legal authority to waive Medicare law is clearly directly only to demo programs, not permanent implementations.  Second, CMMI needed to have clear standards with the Actuary for the agency decision that a program was cost-saving when extrapolated outside the original study.   (If standards are too high, nothing could be expanded, since the expansion always carries financial unknowns).  Third, the CMMI should focus not only on payment policies, but sometimes on technologies were there are serious barriers to innovation that can only be overcome via CMMI's waiver authority.   My comment in the cloud here.