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The Affordable Care Act created the Centers for Medicare & Medicaid Innovations (CMMI), which is tasked with testing demonstration programs aimed at delivery system reform. According to a press release describing feedback to a Request for Information (RFI) on “new directions” for CMMI, the Centers for Medicare & Medicaid Services (CMS) has been engaged in an effort to “collect ideas on a new direction for the agency’s Innovation Center to promote patient-centered care and test market driven reforms that: empower beneficiaries as consumers, provide price transparency, increase choices and competition to drive quality, reduce costs, and improve outcomes.”

The April 23, 2018 CMS press release goes on to announce a new Request for Information, based on feedback received in an RFI issued last fall: “CMS is also taking a next step to develop a potential model in the area of direct provider contracting, informed in part by the RFI. A direct provider contract model would allow providers to take further accountability for the cost and quality of a designated population in order to drive better beneficiary outcomes.”

CMS solicits feedback on a range of issues relating to a potential direct provider contracting (DPC) model, including consumer protections.  However, the overall proposal is so vague and limited in details that it is difficult to tell whether the model could be a re-animation of harmful proposals from the past which would expand current private contracting arrangements between physicians and Medicare beneficiaries (that now require providers to “opt out” of accepting Medicare for a period of time), allow providers to bill above set Medicare limits, or something more benign.

Rather than a more concrete proposal on which to comment, the RFI both explicitly asks and begs far more questions than it answers.  Important issues include: what can providers charge beneficiaries for what services, and will it be more than currently allowed under Medicare rules?  Will beneficiaries be “locked-in” to certain providers?  How would this model coordinate with other coverage, such as a Medigap plan?   Who would this model serve best – more wealthy beneficiaries seeking boutique-type medical practices, or the majority of Medicare beneficiaries?

Despite the vagueness of the proposal, the Center and other advocacy organizations plan to submit comments, including requesting answers to the above questions and more details on the model. We encourage those who are able to comment or raise questions to do so as well.

Comments are due May 25, 2018.

May 10, 2018 – D. Lipschutz

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