Fund Responds to CMS Request for Information about New Directions for the Innovation Center

December 20, 2017

Many recent health care innovation delivery and payment models have been implemented under the direction of the Center for Medicare and Medicaid Innovation (CMMI) housed within the Centers for Medicare & Medicaid Services (CMS). CMS recently issued a request for information (RFI) regarding the future direction of CMMI’s activities, including potential expansion of existing programs and the development of new models.

The Fund submitted two responses focused on several of the topics addressed in the RFI—one response, from the Multi-State Collaborative, a learning network run by the Fund for states working on primary care transformation, and the other inspired by the Reforming States Group (RSG), building on priorities articulated in its Letter to the New Administration, a bipartisan agenda to improve population health.

Alternative Payment Models to Enhance Primary Care

CMS leadership has promoted robust payment incentives as well as broader market impact through Medicare’s support for multi-payer primary care transformation programs. “There is an appetite for these innovations, and if CMS takes action, the states and private payers follow suit,” said Lisa Dulsky Watkins, director of the Multi-State Collaborative. “No matter how strong the leadership at the state or private payer level, our experience of the last 10 years has been that federal leadership around payment reform is essential to driving change.”

There is also untapped opportunity in speeding adoption of alternative payment models through greater and more explicit alignment of state Medicaid payment reform efforts with Medicare payment reforms. “CMS needs to provide sustained policy and operational support for these models, including ongoing administrative funding through CMMI to make sure these programs can demonstrate their full benefit through sustained support,” said Christopher Koller, the Fund’s president.

Read the letter submitted to CMMI from the Fund and local multi-payer collaboratives in support of work on multi-payer primary care transformation.

State and Local Health Care Innovation Models and Behavioral Health Integration

In a separate response to the RFI, the Fund suggested that CMS continue CMMI support of major state policy innovations, such as the comprehensive population-based models being tested in Vermont and Maryland (featured in a 2015 Fund report on health care costs). “Successful state innovation requires strong partnership with the federal government,” said Rachel Block, program officer at the Fund, reiterating a central theme in the RSG’s Letter to the New Administration. Not all states are prepared to take on comprehensive reforms, so CMMI could also support additional states that take on targeted efforts, such as the rural hospital global budget program already approved in Pennsylvania.

The Fund’s second RFI response builds on another theme in the Letter to the New Administration, several behavioral health evidence reports published by the Fund, and feedback from state policymakers. This RFI response suggests that CMS could also help states target resources for integrating behavioral health care with physical health care financing and delivery by coordinating policies and funding support with other federal agencies, such as the Health Resources and Services Administration and the Substance Abuse and Mental Health Services Administration that are responsible for workforce training and service delivery infrastructure.

Read the letter submitted to CMMI from the Fund about state and local health care innovation models and behavioral health integration.

“CMS is already a significant partner assisting states with innovation models through Medicaid and broader, multi-payer efforts,” said Koller. “This is a strong foundation upon which to build, and now we have the opportunity to dramatically enhance the impact of these programs.”