CMS recently released a Request for Information regarding implementation of the Merit-Based Incentive Payment System (MIPS), and promotion of and incentives for alternative payment models (APMs). NRHI submitted a response to CMS on November 17 based on invaluable insights from NRHI members.
The Network for Regional Healthcare Improvement (NRHI) appreciates the opportunity to respond to the above-referenced Request for Information (RFI). NRHI is a national organization representing 40 Regional Health Improvement Collaboratives (RHICs). These multistakeholder organizations are working in their regions and collaborating across regions to transform the healthcare delivery system to achieve better care at a lower cost. The RHICs are accomplishing this transformation by working directly with physicians and other healthcare providers, provider organizations, commercial and government payers, employers, consumers and other healthcare related organizations, to achieve healthcare improvement goals in their respective regions. NRHI and its members are non-profit, non-governmental organizations.
We know that the traditional fee-for-service payment model has proven to be a barrier for achieving reform, failing to provide the right tools and incentives to improve the way care is delivered and improve health outcomes. Congress made important progress in removing this barrier through passage of the Medicare Access and CHIP Reauthorization Act of 2015 (P.L. 114-10) (MACRA), which reforms how physicians are paid and advances payment systems that reward the value, rather than the volume, of care. For these critical reforms to have their desired impact on nationwide health care delivery, they must be implemented in a manner that makes success widely attainable and sustainable.
CMS has a variety of levers it can use to achieve widespread and sustainable reform. It has partnered with RHICs on a variety of delivery system reform initiatives, and the partnerships that have been successful should be continued or expanded as part of the MACRA reforms. MACRA itself also creates a number of new roles, and new opportunities for partnership with entities like RHICs that are already playing many of these roles in their communities. For instance, there will be roles for entities to work directly with physicians to assess the new payment systems and models, to convene physicians into virtual groups, to help physicians meet obligations under the MIPS or transition to new payment models, to provide feedback and education to physicians and to work with physicians on activities that improve their practice. To the extent that these roles can be consolidated within one organization or a network of aligned organizations, implementation will be more efficient and manageable for providers and for CMS. NRHI urges CMS to seek ways to align and integrate these various roles at the local or regional level, and give providers a clear path to the various tools they need to succeed in this new value-based payment environment and improve the care they provide to patients. It is through this lens that NRHI offers the following responses to the RFI.