Earlier feedback from oversight committee seen as key to more and better proposals
Oct. 5, 2018 (ACP) – Hoping to improve the development process for new Alternative Payment Models (APMs), the American College of Physicians is urging the federal government to provide feedback on proposals earlier in the process and to increase transparency as well.
The goal is to overcome the current stalemate and encourage the testing and implementation of more APMs, according to Dr. Jacqueline Fincher, MD, who chairs ACP's Medical Practice and Quality Committee.
APMs – intended to provide incentive payments for high-quality and cost-efficient care – came about as part of the Quality Payment Program established by MACRA, the Medicare Access and CHIP Reauthorization Act of 2015. A special committee, called the Physician-Focused Payment Model Technical Advisory Committee, was created to evaluate proposed APMs and make recommendations to the Secretary of Health and Human Services (HHS).
As the gatekeepers of the process, the committee can recommend APMs for testing and implementation, and it has done that for about a dozen models. To date, however, none have been approved by HHS.
In response to the committee's request for feedback, ACP acknowledged its overall support and offered suggestions on how to improve the model submission process for future developers.
“We believe by directly engaging with developers about possible shortcomings in their models and providing feedback earlier in the process, the [committee's] approval process will save developers countless time and energy and yield more fruitful results,” Fincher wrote in a letter to the committee's chairman.
ACP believes the committee should provide feedback after reviewing a developer's preliminary proposal or written letter of intent, not after the APM has been developed, which is how things are done currently. Now, by the time the committee offers feedback to developers, “countless hours and expense would have been put into financial modeling for a payment methodology that may have inherent flaws or concerns at a surface level that could have been addressed much earlier in the process,” Fincher wrote.
Moreover, the committee does not provide instructions on how to remedy or fix any shortcomings, she noted.
“For the best chance of creating a steady pipeline of sophisticated, physician-led alternative payment models, model developers need to be supported by both [the committee] and HHS to the maximum extent possible with data, technical assistance, and specific, tangible feedback, including alternative solutions,” according to the ACP letter.
It noted that committee members “were selected based on their industry expertise … [and are] best-suited to provide constructive suggestions to improve model designs and offer alternative solutions.”
“As it stands, model developers enter into a black box with very little if any feedback until they are essentially at the end of the drafting process,” according to ACP. “This is not a recipe for results.”
Many of the reasons that HHS has ultimately said no to APMs are recurring and include the use of proprietary tools, labeled an “obstacle” by HHS. ACP urged that the committee formally incorporate such HHS objections into its own criteria for evaluating models so that the goals are more closely aligned.
Shari Erickson, ACP's vice president for governmental affairs and medical practice, said that “there simply aren't a lot of opportunities for physicians to participate in or think about participating in an APM—which was the intent of this program.”
However, if the goals of the committee and HHS were aligned more closely, everyone would know what they are looking for and could feel more confident that proposed APMs would ultimately be tested by the Centers for Medicare and Medicaid Services Innovation Center.
“Earlier feedback and engagement will give [developers] a sense that what they are doing is getting at the goals,” Erickson said.
Though physicians may feel frustrated by the lack of movement on APM development, Erickson noted that ACP is actively engaged in pushing the needle forward.
“We understand that there is great interest in more appropriate reimbursement for the types of care that internists provide as we move away from fee-for-service, and we think there is also a lot of opportunity,” she said.
ACP's letter to the committee is available on the College's website.