CHA News

CHA Provides Principles for Alternative Payment Model Design

CHA comments in response to request for information on new direction for CMS Innovation Center

This post has been archived and contains information that may be out of date.

CHA has prepared the attached comment letter in response to the Centers for Medicare & Medicaid Services’ request for information on the development of alternative payment models and the future of the Center for Medicare & Medicaid Innovation (CMMI). CHA shares a number of guiding principles toward new model designs that CMMI has offered in its request for information. For example, CHA agrees that there should be a focus on voluntary models that reduce burdensome requirements and unnecessary regulations to allow providers to focus on providing high-quality, patient-centered care. CHA also shares CMMI’s commitment to transparent model design and evaluation and looks forward to continued engagement as CMMI builds on the experiences of previous alternative payment model participation and continues to move Medicare payments from a volume-based system to a value-based system.

CHA’s letter offers a number of additional guiding principles for the development of alternative payment models, including the robust use of risk adjustment — including for sociodemographic status, where appropriate — to ensure providers caring for more complex patients do not appear to perform poorly on quality and cost measures. CHA also notes its support for removing legal and regulatory barriers to clinical integration, as well as for modifications and waivers to Medicare policies that deny hospitals the flexibility to provide the most efficient and clinically appropriate care.