CMS released the RFI on Oct. 21 as part of an Executive Order instructing the Department of Health and Human Services to pursue policies to strengthen the Medicare program “through alternative payment methodologies that link payment to value, increase choice, and lower regulatory burdens imposed upon providers.” In the RFI, CMS sought guidance and suggestions from stakeholders on improving the agency’s program integrity efforts.
In its response, CHA urges CMS to prioritize provider and contractor education to promote a shared understanding of expectations of complicated Medicare policy across all stakeholders, including providers and Medicare administrative contractors. In addition, CHA urges CMS to streamline — before adopting new approaches to program integrity under a value-based model — the current regulatory frameworks and inconsistent guidance many providers encounter as they engage with CMS in both voluntary and mandatory alternative payment models. CHA’s letter points out that, often, providers find themselves caught in the middle of complex and unclear regulatory guidance, which leads to differing interpretations and application of CMS policy across contractors and other agencies.
Finally, CHA encourages CMS to take several steps to convene stakeholders on all aspects of program integrity. Specifically, CHA urges CMS to revisit the Medicare Technical Advisory Group process to help inform all aspects of provider education and compliance, which will inform program integrity efforts.
CHA will continue to work with CMS to further define future program integrity efforts and welcomes member engagement on these issues.