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As discussed in a previous CMA Alert, the Centers for Medicare & Medicaid Services (CMS) recently issued a Request for Information on a proposal relating to “direct provider contracting” or “DPC” which, according to CMS, “would allow providers to take further accountability for the cost and quality of a designated population in order to drive better beneficiary outcomes.”

The Center submitted comments on May 25, 2018.   As an overarching comment, we noted that “the current proposal is so ambiguous that it is difficult to provide meaningful feedback and specific recommendations without more substance offered.”   

According to Politico Pulse (5/29/18), the Center and other beneficiary advocates were not alone in expressing concern about the vagueness of the proposal.  Reporter Dan Diamond noted that provider groups urged caution, and “CMS needs to either provide more detail about its proposed ‘direct provider contracting’ model or scrap it altogether, several influential groups told the agency.”

Later in the Center’s comments, we stated:

“CMS appropriately states that it ‘wants to ensure that beneficiaries receive necessary care of high quality in a DPC and that stinting on needed care does not occur.’  We appreciate this sentiment, but it does not necessarily mesh with the above-referenced guiding principle of ‘reducing regulatory burden.’  Often, what providers view as burdens, including notice, reporting and other requirements, serve as important oversight tools for the regulator and protections for consumers.  This or other models should not start from a premise of erasing existing rules in an effort to ensure maximum provider flexibility, then seek ways to potentially back-fill vital consumer protections by guessing about what safeguards should be put in place in an undefined model.” 

The Center expressed strong reservations about the proposal, but suggested that “should CMS move forward, at the very least, it must provide other, more fleshed out iterations on which to comment before proceeding further.”

May 31, 2018 – D. Lipschutz

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