Premier Responds to CMS RFI on Bundled Payments

Premier submitted comments to CMS’ request for information (RFI) on the design of a future episode-based payment model. CMS will use responses to the RFI to inform potential future rulemaking or other policy developments on a new bundled payment model that is centered around improving beneficiary care, lowering Medicare expenditures, reducing fragmentation and increasing care coordination across healthcare settings.

In our detailed comments, Premier urges CMS to:

• Focus episodic models on acute conditions or procedures that have defined and well-established care practices or medical protocols.
• Design episodes that are tailored to the specific condition or procedure and needs of the patient, including varying the length of the episode, defining the initial episode trigger and refining what items or services are included in the episode based on clinical protocols.
• Ensure a mandatory episodic model provides meaningful opportunities for participants to take on two-sided risk, including opportunities for upside financial gain and gradual risk options. CMS must also ensure to establish appropriate provider exclusion criteria and provide sufficient information in advance of the model start.
• Grant precedence to providers participating in existing alternative payment models (APMs) when addressing overlap with a new mandatory episodic model. CMS should also provide opportunities for voluntary participation under the new mandatory model.
• Maintain flexibility and establish incentives to support accountable care organizations (ACOs) and episode initiators in developing partnerships that improve care coordination and patient outcomes.
• Adopt new incentives and modify existing policies to support the integration of specialists into ACOs, including supporting ACOs in the development of “shadow bundles.”
• Modify existing episodic target price methodologies to adopt regional or national target pricing, provide greater transparency around trend factors, improve risk adjustments to account for high-cost patients and modify timing of financial reconciliations.
• Advance health equity by improving the collection and standardization of social determinations of health (SDOH) data and by adjusting episodic payment methodologies to ensure target prices appropriately account for the needs of underserved patients.
• Ensure quality measures are relevant to the care provided in the episode and minimize burden for participants.