CMMI Releases Biennial Report to Congress

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In the 2022 Report to Congress issued by the Center for Medicare and Medicaid Innovation (the CMS Innovation Center), the Centers for Medicare and Medicaid Services (CMS) estimates that between October 1, 2020 and September 30, 2022, more than 41 million Medicare and Medicaid beneficiaries (plus individuals with private insurance in multi-payer model tests) have received care from – or will soon receive care from – one of the more than 314,000 health care providers and/or plans participating in the CMS Innovation Center payment and service delivery models and initiatives.

During that same timeframe, CMS Innovation Center tested, announced, or issued Notices of Proposed Rulemaking for 32 payment and service delivery models and initiatives and conducted six congressionally mandated/authorized demonstration projects.

The CMS Innovation Center was established in 2010 and in the last decade, the CMS Innovation Center launched more than 50 model tests, with about 33 models operational during the two years covered by the report.

Since the start of the CMS Innovation Center, six model tests have delivered statistically significant savings, net of any incentive or operational payments: the Pioneer ACO Model; the ACO Investment Model (AIM); the Medicare Prior Authorization Model: Repetitive Scheduled Non-Emergent Ambulance Transport (RSNAT); the Home Health Value-Based Purchasing (HHVBP) Model; the Maryland All-Payer (MDAPM) Model; and the Medicare Care Choices Model (MCCM).

Additional models showed improvement in quality or reduced low value care and generated gross (but not net) savings, including the Comprehensive Care for Joint Replacement (CJR) Model; the Comprehensive End-Stage Renal Disease (ESRD) Care (CEC) Model; the Oncology Care Model (OCM); and the Million Hearts®: Cardiovascular Disease Risk Reduction Model. While these models did not meet eligibility for expansion, they do continue to have “a meaningful impact on the CMS Innovation Center’s work, and longer-term goal of realizing a health care system that achieves the equitable outcomes through high quality, affordable, person centered care.”

Cost Savings and Quality Improvement

During the report period, CMS Innovation Center model tests reported net cost savings and quality improvement. Specifically, in May 2021, the final evaluation report of the RSNAT Model indicated $1 billion in total Medicare savings among Medicare beneficiaries with end stage renal disease and/or pressure ulcers over its first 20 quarters (beginning December 2014) relative to the comparison group, averaging a savings of $381 per-beneficiary-per quarter. The model was expanded nationwide in 2019.

The HHVBP Model had previously been implemented in nine states. In October 2020, the CMS Chief Actuary certified that if the program were expanded, it would reduce (or at the least, not result in any increase in) net program spending. The April 2022 annual evaluation report showed a cumulative net savings of nearly $1 billion in the first five years of the model. The HHVBP Expanded Model began its pre-implementation year on January 1, 2022.

Physician Focused Payment Models

The report also included a section on the Physician-Focused Payment Model Technical Advisory Committee (PTAC). PTAC meets roughly once a quarter to review proposals that are submitted by stakeholders, deliberates, and votes on whether each proposal meets the criteria for a Physician Focused Payment Model. If it does, PTAC submits it to the Secretary of the Department of Health and Human Services (HHS) for review and response.

CMS has drawn from PTAC’s recommendations and comments and has ultimately incorporated several Physician Focused Payment Model design elements into some of the CMS Innovation Center’s payment and service delivery models. Some of the examples provided in the report include proposals from Renal Physician Associates and Dialyze Direct influenced the design of the CMS Innovation Center’s Kidney Care Choices Model; proposed models from the American Academy of Family Physicians, and University of Chicago Medicine helped to shape the Primary Care First Model; and a proposed model from the Illinois Gastroenterology Group led to the incorporation of irritable bowel disease episodes into the Bundled Payments for Care Improvement Advanced Model.

Equitable Outcomes

In October 2021, CMS set out a vision for achieving equitable outcomes through high-quality, affordable, and patient-centered care. To achieve those outcomes, the CMS Innovation Center established five strategic objectives: drive accountable care, advance health equity, support innovation, address affordability, and create partnerships to achieve system transformation.

CMS also noted that when moving forward, the CMS Innovation Center will assess model tests’ quality-related impacts on health equity, person-centered care, and health system transformation.

Conclusion

The CMS Innovation Center continues to work towards protecting taxpayer dollars and patient care. The Center will continue to focus on “innovative payment and service delivery models designed to reduce program expenditures while preserving or enhancing the quality of care furnished.”

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