Physicians are calling on a new federal advisory committee to be sure to include specialists in the coming value-based alternative payment models.
Created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), the Physician-Focused Payment Model Technical Advisory Committee (PTAC) is charged with providing comments and recommendations on physician payment models to the Health & Human Services department. At the committee’s first meeting on Feb. 1, members heard from a number of physician associations that expressed disappointment about the role of specialists in current value-based payment models and requested more attention as new models move forward.
“We believe [the Centers for Medicare & Medicaid Services] needs to allow for the widest range of innovative ideas to ensure the greatest number of physicians are not only able to participate, but succeed in future payment models,” said Jenna Kappel, health policy director for the American Academy of Otolaryngology–Head and Neck Surgery. “We are hopeful there will be opportunities for specialists to participate and thrive in [alternative payment models] in the future. However, the current CMS definition of an alternative payment entity provides very limited opportunities for models that include the participation of specialists.”
The American College of Emergency Physicians concurred.
“There have been a significant number of [Center for Medicare & Medicaid Innovation] grants and state Medicaid proposals that include an emergency department [ED] visit as a failure metric,” said Barbara Tomar, federal affairs director for ACEP. “We understand that to a certain point ... but there are always going to be a proportion of patients [who] have serious diseases or conditions that will have exacerbations, and they’re going to land in the ED. This really should be acknowledged in a lot of the alternative payment models.”
Committee members acknowledged concerns about APMs and outlined goals for developing an effective proposal review process.
“We need to involve everybody in developing innovative payment models that do away with all frustration that physicians are currently experiencing and get to better results and higher value,” said committee member Robert A. Berenson, an internist and former vice chair of the Medicare Payment Advisory Commission. “At the same time, these payment models not only have to be elegant in their conception, but they have to be operationally and administratively feasible. ... They need to be such that most payers can adopt them, not simply CMS or Medicare or a state Medicaid agency,” Dr. Berenson said.
Transparency, inclusion, and education are primary aims of the committee, said committee member Dr. Kavita Patel, an internist and senior fellow at the Brookings Institution, Washington.
“Part of my responsibility, having looked at other payment models as well as the trials and tribulations of not just the practicing clinician, but the practicing team is [considering] how the team is going to adapt and learn and strive in this environment,” Dr. Patel said. “So much of what we try to do is think about the financial incentives. We also need to think about what are we asking clinicians to measure? What are we asking patients and families to report on and how do we have the two align?”
Officials at the CMS Innovation Center have said that proposed APMs will be submitted first to PTAC for recommendations and then will go to HHS. The Secretary will make comments about the proposals on the CMS website, followed by testing consideration. Potential evaluation factors include the strength of the evidence base, the potential for cost savings, the probability of model success, feasibility, scalability, and demographic, clinical, and geographic diversity.
“Obviously, we’re not looking for slam dunk data that say it always will be effective because if it were, we wouldn’t need to do the test, but we need some evidence that this is potentially a worthwhile investment,” said Dr. Hoangmai H. Pham, director of accountable care programs at the CMS Innovation Center.
CMS officials stressed that models should be designed as broadly as possible. A proposal can include multiple interventions, but should include a similar theme, procedure, or condition to address.
“It gives us the opportunity to find efficiencies,” Dr. Pham said. “It’s much easier to have one model with multiple tracks that you can ask one application contractor to handle as opposed to six. Much easier to ask for all the payment shared system changes in 1 change request rather than 32. That’s another reason we would urge you to favor comprehensive models.”
CMS officials plan to issue a proposed rule on APMs in April and a final rule Nov. 1.