Created under the Obama-era Affordable Care Act, CMS’s Center for Medicare & Medicaid Innovation (CMMI) is about to undergo a transformation.
The first step was seeking public comment last fall to collect ideas on a new direction for CMMI—and last week CMS released the over 1,000 responses to its RFI (Request for Information) from a wide variety of individuals and organizations. Over the coming year CMS will use the feedback as it works to develop new transformative models as well as to improve existing models. HHS/CMS leadership insists such innovation should empower patients with more choices and better health outcomes, while via efficiencies save Medicare and Medicaid dollars.
Among the comments, the National Association for Home Care & Hospice (NAHC) noted: “We strongly endorse the initiation of a model under the Innovations Center that tests a value-based fee-for-service model that provides care management delivered by an inter-disciplinary team for patients with advanced illness who are believed to be entering the final year of life.”
Under an “Advanced Illness/Palliative Care Model” the patient would have access to palliative care and support services, coordinated care, and advance care planning discussions. “Coordination of care efforts would ensure closer oversight of patients, encourage more timely care interventions and referral to less acute care settings such as home health, and reduce the incidence of acute exacerbations, including hospitalizations,” NAHC stated.
CMMI Interested in Testing Models in 8 Focus Areas
The Model could relate to one or more of CMMI’s “focus areas,” which were stated in the RFI: (1) Increased participation in Advanced Alternative Payment Models (APMs); (2) Consumer-Directed Care & Market-Based Innovation Models; (3) Physician Specialty Models; (4) Prescription Drug Models; (5) Medicare Advantage (MA) Innovation Models; (6) State-Based and Local Innovation, including Medicaid-focused Models; (7) Mental and Behavioral Health Models; and, (8) Program Integrity. However, the Innovation Center may also test models in other areas.
In its 14-page comments to CMS, ElevatingHOME urges the Innovation Center “must include home-based care agencies at the center of value-based purchasing models.”
ElevatingHOME “supports a fully integrated care network convened by home agencies including all clinical providers and medical services needed by patients to lead to reduced re-hospitalizations and effective transitions from acute care settings to home.” Qualified home-based care providers “should have the flexibility to design benefits and services as needed for their patients to allow for more comprehensive and patient-centered care. This flexibility would include the ability to waive restrictions on eligibility for home health services, limits on the amount, frequency and duration of home health services, and the prohibition on free preoperative home safety assessments.”
A relatively new industry organization launched to unify for-profit and not-for-profit home health and hospice providers, ElevatingHOME notes The Innovation Center “should promote policies that tackle waste, fraud and abuse—without adding to the regulatory burden on home health agencies.”
Aetna commented it allows commercial members with a life expectancy of up to 12 months to elect hospice and to continue receiving some curative services while in hospice. “While Medicare beneficiaries are eligible for hospice care if their life expectancy is six months or less, we believe CMS should develop a demonstration to test the efficiencies of allowing MA beneficiaries to elect hospice with a longer life expectancy, while allowing plans to continue to offer some curative services, similar to the FFS model that is currently being tested.”
In addition to the themes that emerged around the RFI’s guiding principles and eight-model focus areas, the comments received in response to the RFI also reflected broad support for reducing burdensome requirements and unnecessary regulations, which in the comments include but are not limited in post-acute to: revising face-to-face encounter documentation requirements; testing the impact of waiving the “homebound” requirement on access to home-based care; and, amending the current definition of a “visit” to also include remote, virtual, or telehealth visits.
New CMMI Director, Landmark Founder Adam Boehler
With a new direction for CMMI comes a new director of the office. Health and Human Services Secretary Alex M. Azar II recently appointed Adam Boehler as CMS Deputy Administrator for Innovation and Quality, and Director of CMMI. Boehler is the former CEO and founder of Landmark Health--a company focused on delivering medical services to the most chronically ill patients. He is also the founder of Avalon Health Solutions--a leading provider of laboratory benefit management services in the U.S.
By: Ronald M. Schwartz, Writer, The Remington Report