- The Premier healthcare alliance made a total of ten recommendations to House Committee on Ways and Means Subcommittee on Health to provide regulatory relief to the healthcare industry, which include monthly data sharing by CMS as part of the Quality Payment Program.
The alliance representing 3,900 hospitals and over 150,000 provider organizations contended that federal mandates Premier will obstruct innovation, increase costs, and negatively impact patient care delivery.
Premier developed its recommendations around several guiding principles including increased transparency, appropriate timelines, increased flexibility, appropriate quality measures, reduced program overlap, and improved data access.
Additionally, the alliance cautioned against CMS rushing providers into new initiatives.
“Too often in the recent past the Centers for Medicare & Medicaid Services (CMS) has pushed through new programs and initiatives without giving thoughtful consideration to the resources and time needed by providers to implement these programs in an effective way without disrupting the health care provided to beneficiaries,” wrote Premier.
While also recommending that participating in the Alternative Payment Model (APM) portion of the Quality Payment Program be voluntary, the alliance insisted that participating accountable care organizations should have access to substance use data on their patients:
Providers engaging in ACOs, bundled payments and other models should be able to access their patients’ medical records on substance use — information that is needed for providers to understand the totality of a patient’s care needs and provide safe, effective and coordinated treatment. Requiring individual patient consent for access to addiction records from federally funded substance use treatment programs, as current requirements do, is an obstacle to an integrated approach to patient care.
Other recommendations extend to
- Availability of technical information when proposing new payment models
- Support for a new Bundled Payment for Care Improvement (BPCI) model
- Flexibility in payment rules and legal requirements
- Additional waiver expansions
- Clinical quality measures for each model
- Alignment of various alternative payment models
- Recovery Audit Contractors (RACs)
- The Medicare Outpatient Observation Notice (MOON).
To support stakeholders in adjusting to new payment models as per Premier’s first recommendation, the alliance recommended CMS provide data and examples to providers online along with proposed models. Offering providers an example to follow would ease confusion around fulfilling requirements.
“CMS should allow organizations to apply for a national file to not only calculate individual participant performance, but also national factors,” the alliance added.
Premier also offered potential solutions for ways CMS can allow participant groups more time to assimilate to payment models before introducing new ones.
“CMS should proceed slowly and deliberately to bring all of the bundling programs under a single, consistently structured umbrella that is constructed through the public rulemaking process,” Premier stated.
The association also recommended CMS incorporate a timeline for participants and their collaborators reflecting how long they have to prepare for the beginning of a new model and to continue steadily adjusting to the model’s rising expectations.
“Requiring model participants to meet higher targets in quality and cost during five-year models fosters progress towards alternative care delivery systems,” the alliance wrote. “Initial and subsequent requirements, however, need to be reality-grounded.”
To better align quality measures with the clinical focus of each model, Premier suggested CMS focus on specificity.
“CMS should focus only on developing models for which a sufficient number of specific quality measures can be identified prospectively,” wrote Premier. “Further, CMS should give explicit consideration to potential negative interactions among models on quality data generation during the rulemaking process.”
“The number of measures should be manageable and the measure submission methods should be facile for participants,” continued Premier.
These and other potential solutions are designed to simplify requirements and regulations for providers and allow sufficient time to adjust to any program changes.
AHA also recently submitted comments to the Ways and Means Health Subcommittee requesting CMS eliminate Stage 3 Meaningful Use requirements, along with 41 other recommendations.
Similar to Premier, AHA also emphasized the need to ensure quality measures are as focused and necessary as possible.