June 1, 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
Dear Director Boehler,
We, the undersigned, write to follow up on a previous letter sent by healthcare industry stakeholders asking your Agency to recognize physician participation in risk-bearing contracts in Medicare Advantage (MA) toward the Advanced Alternative Payment Model (Advanced APM) participation criteria as outlined in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
If we are truly committed to moving our nation’s delivery system away from volume-based compensation and towards payment for value and high-quality care, we must ensure provider incentives are aligned in both traditional Medicare and MA to incent participation in risk-bearing alternative payment models. As you know, there is evidence that risk-bearing contracts in MA deliver care that is of higher quality and lower cost than care delivered in fee-for-service based MA, yet these providers still aren’t afforded credit under MACRA.
As you know, the Centers for Medicare & Medicaid Services (CMS) recently opened an Advanced APM portal for MA plans which allows the plans to request that their payment arrangements with providers receive an "other payer advanced APM determination" under the Quality Payment Program (QPP) mandated by MACRA. In the 2019 performance year, eligible clinicians may use their other payer risk contracts in combination with participation with an Advanced APM in traditional Medicare to qualify for the 5 percent bonus under the Advanced APM track. However, physician groups must still meet the 25 percent revenue threshold in traditional Medicare to qualify. For many physicians in areas of the country with heavy MA penetration, this is not achievable. Risk contracts should and must be treated equally across traditional Medicare and MA to truly advance the value movement.
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