ACOs Call for Transparency in CMS Alternative Payment Model Design

In a letter to CMS, NAACOS calls for increased transparency in the development of alternative payment models.

By Jessica Kent

April 03, 2019 - The National Association of ACOs (NAACOS) has urged the CMS Innovation Center to improve transparency throughout the process of releasing and updating alternative payment models.

“While we appreciate steps the agency has taken, such as hosting stakeholder roundtable discussions to gather input, we ask that the Innovation Center move to a more methodical and public process for releasing and updating payment models,” the organization stated in a letter to CMS.

To enhance participation in alternative payment models, NAACOS recommended that CMS move Innovation Center models to a public process that includes opportunities for stakeholders to comment on all model design elements. Model changes should also be communicated in a clear and public manner, NAACOS said.

“As you know, responsibly moving to higher levels of financial risk requires a steady and predictable payment environment. This allows organizations to plan their budgets and care coordination activities and to predict how they will fare under any given model,” the organization stated.

“Creating a clarity and stability for model design will encourage provider organizations to move to higher levels of risk and reward more quickly.”

NAACOS also suggested that CMS establish a payment model process that is similar to those used in other programs, such as the Medicare Advantage Rate Notice and the State Medicaid Director Letters.

These programs require that certain updates and policy changes be communicated publicly, with some opportunity for stakeholder feedback, but without the formality of notice and comment rulemaking. The organization also recommended that CMS remove mid-year changes from the model process, which will improve stability among model participants.

“In the current Innovation Center models, changes are often communicated through contract amendments – sometimes in the middle of a performance year,” NAACOS said.

“As part of this new process, we request that the Innovation Center refrain from making mid-year changes, which have a significant programmatic or financial impact on model participants, and therefore create tremendous destabilization given the many decisions model participants make based on their unique circumstances and projections going into the performance year.”

NAACOS expects that public communication of model changes, as well as the elimination of mid-year changes, will help providers evaluate and compare their payment model options.

“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 organization said.

NAACOS believes that these recommendations will help accelerate healthcare’s shift to alternative payment models and value-based care.

“We are excited to continue to work with the Innovation Center to pursue new models, many of which will feature increasing levels of financial risk and reward. We are confident that this is the right direction to create a sustainable healthcare delivery system for the future,” NAACOS concluded.

“We are committed to this transition and look forward to working with you to continue to advance this movement. Together, we can develop delivery and payment systems that improve the nation’s health and fiscal outlook.”

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