May 24, 2018
Mr. Adam Boehler
Deputy Administrator for Innovation and Quality
Director, Center for Medicare & Medicaid Innovation
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244
Submitted via email at DPC@cms.hhs.gov
Re: Center for Medicare and Medicaid Innovation Request for Information on Direct Provider Contracting
Dear Deputy Administrator Boehler:
The Medical Group Management Association (MGMA) appreciates this opportunity to provide feedback regarding the draft direct provider contracting (DPC) model. We support the Center for Medicare and Medicaid Innovation’s goal of increasing participation in Advanced Alternative Payment Models (APMs) by creating additional opportunities that encourage provider flexibility and choice and reduce burdensome regulations and one-size-fits-all requirements. MGMA commends the Innovation Center for seeking stakeholder input at the outset of DPC model development, and we look forward to an ongoing, constructive dialogue as model details are refined.
Since 1926, MGMA has been the premier association for professionals who lead medical practices. With a membership of more than 40,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 organizations of all sizes, types, structures, and specialties that deliver almost half of the healthcare in the United States.
Before commenting specifically on the proposed DPC model, the Association wishes to emphasize our support for the Innovation Center’s recent actions to reduce or eliminate mandatory participation requirements in several bundled payment models and to develop the voluntary Bundled Payments for Care Improvement (BPCI) Advanced APM. Despite general support for APMs, a large majority of physician group practices oppose government-mandated participation due to a lack of evidence that joining an APM leads directly to more efficiently delivered care and better patient outcomes, significant diversity among group practices, and the potential negative impact on practice innovation. Physician group practices overwhelmingly prefer flexibility and financial incentives over mandates when considering participation in an Advanced APM. While offering Advanced APM opportunities on a voluntary basis may lead to self-selection by participants that expect to do well on performance metrics, these industry leaders can establish the value proposition and thereby encourage other organizations to move to Advanced APMs.
May 24, 2018