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    Mollie Gelburd
    Mollie Gelburd, JD

    The Medical Group Management Association’s most recent MGMA Stat poll asked healthcare leaders, “Should the government mandate participation in Medicare alternative payment models?” Only 10% responded “yes,” showing that the vast majority (76%) of respondents prefer flexibility and choice in value-based payment reform. The other 14% responded “unsure.” 

    The poll was conducted Oct. 20, 2020, with 802 applicable responses.

    There has been significant attention to transitioning the current healthcare payment system away from traditional fee-for-service, which pays providers based on volume of services, to alternative payment models (APMs) that pay for value, such as improving patient outcomes in a cost-efficient manner. Despite attention to this issue, the government has shown little aptitude toward implementing value-based care reform. 

    The Centers for Medicare & Medicaid Services (CMS), through its Innovation Center, is charged with testing APMs yet has been frustratingly slow in producing new options. In an effort to spur innovation, CMS Administrator Seema Verma recently made concerning remarks that CMS will implement more mandatory models in the future.

    MGMA continues to strongly support efforts to improve value-based payment but does not agree with mandating participation in payment models that are untested and lack evidentiary support. Joining an APM is an important business decision that should be made by a group practice, rather than a mandate by the government. There is no single approach to APMs that will work for all practices or specialties, which is why multiple, voluntary models are needed so that providers can test new designs for care and payment delivery. 

    CMS: More mandatory APMs on the horizon

    In recent weeks, CMS Administrator Verma and Innovation Center Deputy Administrator and Director Brad Smith have expressed disappointment with results from existing APMs, noting there is an urgent need for a “course correction” because current models are not producing enough savings for Medicare. Moving forward, Medicare leadership stated it will require more physician groups to participate in new payment models that will feature greater financial risk and fewer opportunities for financial reward. Rather than offering financial incentives for model participants, CMS states it favors offering regulatory flexibility as a benefit. 
    These remarks are disappointing and fail to recognize group practices that have voluntarily participated in APMs, improved care delivery, implemented changes to reduce costs, and contributed to efforts to understand what is working. Not only is mandatory participation a significant concern, the new direction outlined by Medicare leadership conveys a narrow focus on savings to Medicare. 

    Payment reform must include adequate reimbursement rates, incentives, and supports, and must strike an appropriate balance between offering financial incentives for those that achieve model goals and generating savings to the Medicare Trust. Requiring group practices to move into new payment models that lack adequate financial incentives but entail significant downside risk creates an untenable path forward.

    MGMA supports voluntary models with appropriate rewards

    Rather than taking a shortcut to boosting numbers by mandating participation in APMs, CMS should focus on continuing to develop new models that meet the needs of a diverse range of practices of varying types, sizes and specialties, which will inherently drive more widespread participation. It is critical that CMS gives providers the choice to participate in an APM because not all group practices will be prepared to make the changes necessary to succeed in new delivery models. 

    MGMA will continue to leverage member feedback, such as the results of this poll, to articulate our position against mandatory APMs and support for more voluntary models that offer opportunity for reward in the form of shared savings and other incentives. 

    Additional resources:

    • MGMA joins coalition of specialty societies urging delay of mandatory radiation oncology model 
    • Learn about different types of ACOs 
    • Explore resources on MACRA’s payment tracks 


    Our ability at MGMA to provide great resources, education and advocacy depends on a strong feedback loop with healthcare leaders. To be part of this effort, sign up for MGMA Stat and make your voice heard in our weekly polls. Sign up by texting “STAT” to 33550 or visit Polls will be sent to your phone via text message.

    Mollie Gelburd

    Written By

    Mollie Gelburd, JD

    Mollie Gelburd serves as a member liaison for MGMA Government Affairs and has broad expertise in the details of federal legislative and regulatory issues and their impact on group practices. She coordinates Association grassroots efforts and is a frequent speaker at MGMA state and national meetings. Previously, she worked as an attorney advisor at the Social Security Administration. Mollie earned a law degree from The Catholic University of America, Columbus School of Law and a bachelor's degree in political science from Radford University.

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