Society Submits Comments on Direct Provider Contracting RFI

The Centers for Medicare & Medicaid Services (CMS) recently released a request for information (RFI) asking for input on direct provider contracting (DPC) between payers and primary care or multi-specialty groups to inform potential testing of a DPC model within the Medicare fee-for-service (FFS) program (Medicare Parts A and B), Medicare Advantage program (Medicare Part C), and Medicaid.

The Society submitted a response to the request that noted “direct provider contracting model could be a viable payment model for PALTC clinicians and afford opportunities to incentivize physicians to work and provide quality care in the PALTC setting. We feel the crucial goal of these models should be to meaningfully reward physicians for higher quality care while simplifying reporting requirements.”

The RFI asked what features CMS should require practices demonstrate to participate in a DPC model. The Society noted that the models would need flexibility for practices that may not be using CEHRT, clear staffing requirements (whether the work is performed at a facility or office), and the difference of populations within skilled nursing facilities (short-term stays) and nursing facilities (long-term stays).  

The Society also said that it, “strongly believes that CMS must invest resources in working with societies like AMDA and other stakeholders in the PALTC arena to develop infrastructure for an Advanced Alternative Payment Model” as there are currently no such models available for PALTC based clinicians. This includes providing current available data for this population to work on an appropriate risk adjustment model and appropriate quality metrics. “It is difficult for PALTC practitioners to bear the risk of an up-front cost in these models given that there are no specific pathways for an Advanced Alternative Payment Model or even any shared risk participation” stated the letter. CMS should develop models centered around the unique challenges of PALTC physician practices that take care of a population with dementia, substantial functional impairment, medical frailty, and other costly chronic conditions. Further, “Physicians control much of the care provided but up until this point have been left out of cost-sharing opportunities that are afforded to hospitals and other specialty practices. We strongly believe that incenting physicians into these types of arrangements with appropriate risk adjustment and quality metrics will get them more involved in the care of PALTC patients and lead to better outcomes at lower costs.”

The Society went on to say that “Our members care for some of the sickest and most costly Medicare beneficiaries, the frail elderly residing in institutions. Much of that cost, especially in PALTC, is attributed to hospitalizations and the care provided subsequent to a hospitalization (including post-acute utilization and hospital re-admissions). We strongly believe designing a payment system that incentivizes trained clinicians to be heavily engaged with their facilities through a shared-savings mechanism based on reduced hospital costs will improve patient outcomes and significantly reduce overall costs for CMS for this frail elderly population.”

To read all the Society’s comments click here.