WASHINGTON -- A panel of physicians and other healthcare experts charged with vetting new payment models for the Centers for Medicare & Medicaid Services (CMS) told stakeholders to think more broadly at a meeting here on Friday.
"People are trying to fit square pegs into round holes," said Harold Miller, president and CEO of the Center for Healthcare Quality and Payment Reform in Pittsburgh.
Stakeholders are continually saying, "I gotta have a bundle. I gotta have an episode," he told MedPage Today after the meeting, noting that there are so many more options.
"[I]f we were going to create a new way of being paid ... that was about the best possible outcome for patients, irrespective of facility fees or whatever... What would it look like?" asked Grace Terrell, MD, president and CEO of Cornerstone Health Care in Greensboro and Winston-Salem, N.C.
Terrell and Miller are members of the Physician-focused Payment Model Technical Advisory Committee (PTAC), which was established by Congress under the 2015 Medicare Access and CHIP Reauthorization Act. That legislation repealed and replaced the much-reviled Sustainable Growth Rate (SGR) formula.
The committee's job is to review proposals for physician-focused payment models (PFPMs) -- a.k.a. alternative payment models -- and then advise the Secretary of Health and Human Services (HHS) about whether the proposals meet the secretary's criteria for PFPMs. HHS has already issued draft criteria for PFPMs; definitive criteria, in the form of a final rule, are expected in November.
At Friday's meeting, stakeholders shared concerns about the availability of technical assistance from the committee and the challenge of accessing data to support their ideas.
"One of the hardest things to do is to prove that you're saving because of care and hospitalization and other services that are avoided," said Eileen Carlson, RN, JD, of the American Psychiatric Association.
The committee said it plans to release a list of publicly available data sources on Friday and has asked for more feedback regarding both the specifics of stakeholders data concerns and their technical assistance needs.
"We don't know what we don't know, and we don't know what you don't know," said Terrell.
The committee recently released a revised draft of the Physician-Focused Payment Model Technical Advisory Committee Proposal Review Process. PTAC also released its Proposal Information Requirements, which are based on the draft criteria the Secretary released on May 9, 2016. The goal of Friday's meeting was to solicit feedback on its proposal and processes and to discuss the draft criteria.
PTAC said it plans to release a draft request for proposal (RFP) next week and will accept comments on that document for 30 days.
To begin to have a PFPM reviewed a stakeholder must submit a 2-page, non-binding "letter of intent" 30 days prior to the actual proposal submission, and include the following information, as outlined in the revised draft of the PTAC Proposal Review Process :
- the expected participants
- the goals of the payment model
- an overview of the payment model structure
- a description of the provider organization implementing the proposed model
- a date when the organization expects to submit the proposal
Once the final criteria are established, on or before November 1, the PTAC will issue a request for proposals and anticipates receiving proposals by December, 2016. The Committee said it plans to hold online education sessions and post Frequently Asked Questions about the process; however, according to the current draft of the review process, it will not provide support to individual stakeholders.
No proposal will be accepted unless the committee receives a letter of intent at least 30 days prior; PTAC pledges to acknowledge receipt of the letter within 2 days.
Following the submission of a letter of intent, stakeholders can submit their proposals; the committee will assign each proposal to a preliminary review subgroup, which will write a preliminary review, obtain additional expertise, solicit public comment for 3 weeks, and then deliver a written report on each proposal to the full PTAC committee.
Each preliminary review team must include at least one physician. Review teams must complete their report within 2 weeks of either the end of the public comment period, or the date on which the individuals submitting a proposal sent any answers or additional information, whichever is later. The full committee will then review the proposal and then make a recommendation on whether it should be accepted.
The full review process, from submission to recommendation, is anticipated to last 16 weeks -- a timeframe the committee describes as "ambitious."
In its draft document, the committee noted, "If a proposal is not recommended by the PTAC, the submitter can revise and resubmit the proposal and it will be reviewed through the same process used for the original submission."
The window for commenting on the PTAC proposal review process will close Oct. 10.