Regulations implementing the Medicare Access and CHIP Reauthorization Act (MACRA) and other existing laws should include the following key elements:
- Strong financial incentives for hospitals to provide high quality care, including reduction of avoidable readmissions and hospital-acquired conditions.
- Strong financial incentives for physicians to provide high quality care.
- Establish an explicit timeline to incorporate prospectively set payments for comprehensive bundles (facility, professional and drugs) in all CMS episode-based payment programs.
- Requirements for public reporting of meaningful and useful performance measures, as well as funding for the rapid development and testing of new measures to fill existing gaps.
- Require all Medicare alternative payment models to include meaningful and useful publicly-reported measures of clinical outcomes, patient-reported outcomes (PROs) and patient experience.
- Definitions of Alternative Payment Models under MACRA that support full accountability and meaningful financial incentives for quality, patient experience and total cost of care.
- Federal programs must continue to partner in value-promoting efforts. The Center for Medicare and Medicaid Innovation (or a similar organization with authority to test and spread innovative provider payment and care delivery models) and the State Innovations Model program should remain fully funded and operational.
Consumer Engagement and Financial Incentives
- Modify requirements for use of Health Savings Account (HSA) Eligible High-Deductible Health Plans (HDHPs) to allow first-dollar coverage for costs up front that will tend to improve health and reduce outlays later.
- Enable chronically ill Medicare beneficiaries to have lower cost sharing for high-value Chronic Care Management (CCM) services. Providers accepting upside and downside financial risk should be permitted to reduce or waive patient cost-sharing (including co-pays, co-insurance and deductibles) for high-value CCM services.
- Allow Medicare Advantage plans more flexibility to experiment with Value-Based Insurance Design (VBID) for patients with chronic conditions.
Alternative Payment Models
- Incorporate larger financial incentives for providers taking on two-sided performance risk under all federal alternative payment models, including those under MACRA.
- Include an opt-in approach for the Medicare Accountable Care Organization (ACO) program that may include enhanced benefits for engaged beneficiaries.
- Re-examine and relax the limitations on the use of telehealth services in Medicare for providers accepting accountability for quality, patient experience, and total cost of care.
Transparency and Performance Measures
- Support the creation of aggregated databases that pool data from various sources, including clinical data from providers and hospitals as well as insurance claims data, to provide information regarding aspects of quality, efficiency, and price. Data collection and reporting standards and processes should be harmonized across states to minimize the administrative costs of data reporting for providers and insurers.
- Ensure health plan enrollees (including those in the Federal Exchanges and Federal Employee Health Benefits Program) have meaningful and useful quality information and price calculators that include plan- and provider-specific total costs and expected out-of-pocket costs for common inpatient and outpatient procedures and conditions.
- Reinforce and accelerate interoperability requirements for electronic medical records and patient-generated data. Strengthen incentives for providers to demonstrate meaningful use of interoperable EHRs under MACRA.