By Blair Childs, Senior Vice President of Public Affairs
Members of the Premier alliance strongly support the expansion of alternative payment models (APMs) for providers, including new models for cardiac and orthopedic procedures. Bundled payment models have been shown to incent care coordination, quality improvement and cost containment. Moreover, we commend CMS for recognizing that these models need to conform with the definition of advanced alternative payment models, as outlined in MACRA, for the purposes of allowing qualified professionals to earn a 5 percent bonus.
We also applaud CMS for taking another step toward testing an MSSP Track 1+ Advanced APM model, including many structural elements advocated for by Premier, such as an ability to move into Track 1+ mid-contract, an option to use a 3-day stay waiver, and asymmetrical risk and reward sharing. Despite this, we are disappointed by CMS’s requirements for risk. Rather than follow the MACRA final rule, which reduced the nominal risk level from 4 to 3 percent of total expenditures, this proposal increases it again to 4 percent. For health systems that by and large will rely on the total cost of care threshold for nominal risk, we continue to believe that this level of risk is excessive and will discourage many qualified providers from moving into Advanced APMs.
-By Blair Childs, Senior Vice President of Public Affairs