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CMS Requests Industry Feedback on "New Direction" for the Innovation Center

Health Law Alert

CMS is seeking comments through a Request for Information (RFI) on a "new direction" for the CMS Innovation Center. The RFI includes focus areas identified by CMS, but the RFI welcomes all stakeholder input on "additional ideas and concepts," including the "future direction of the Innovation Center." This is an opportunity for stakeholders to provide feedback or suggest new ideas that could shape the Innovation Center's policies and priorities on future payment models. The deadline to submit comments to the RFI is November 20, 2017.

The Innovation Center is responsible for testing new payment and service delivery models and had been busy introducing new bundled payment models until the change in administration. Coinciding with the change in administration, the Innovation Center has scaled back the mandatory nature of participation in bundled payment models, like the Comprehensive Care for Joint Replacements Model, or canceled implementation of other bundled payments models altogether, such as the Episode Payment Models. (For further discussion, see "CMS Cancels EPM and Cardiac Rehabilitation Incentive Program While Revising CJR in New Proposed Rule.")

In combination with the above bundled payment model changes, the RFI is setting a new course for the Innovation Center, a course that is veering towards voluntary participation in payment models instead of mandatory participation. Prior to his resignation, former Secretary of Health and Human Services, Tom Price, M.D., had taken a critical stance towards the Innovation Center's mandatory models. Although the administration seems committed to the transition away from fee-for-service, this RFI, among other actions, are looking to increase voluntary participation opportunities for providers instead of mandating their participation.

The RFI mentions particular interest in receiving comments in the following eight focus areas identified by the Innovation Center:

  1. Increased participation in Advanced Alternative Payment Models;
  2. Consumer-Directed Care & Market-Based Innovation Models;
  3. Physician Specialty Models;
  4. Prescription Drug Models;
  5. Medicare Advantage Innovation Models;
  6. State-Based and Local Innovation, including Medicaid-focused Models;
  7. Mental and Behavioral Health Models; and
  8. Program Integrity.

Given the broad nature of the RFI, stakeholders have an opportunity to influence the "new direction" of the Innovation Center and can submit comments to the RFI until November 20, 2017. 

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