The CMS Innovation Center announced their 10-year vision. The whitepaper is incredibly boring.
To save you time, here are the Innovation Center’s six lessons learned from their first decade, along with my guesses as to what we can expect policy-wise for the next decade.
Lesson 1: Ensure health equity is embedded in every model
- Most Innovation Center models have been focused on Medicare (because it costs the government more than Medicaid does).
- Most models have been opt-in, meaning that providers with a greater appetite for risk have joined, while others have stayed on the sidelines.
- This has meant the patients who have benefited from Innovation Center models have been richer and whiter than the population at large. Expect the next set of models to have special perks to attract providers who care for underserved populations (in the CMS lexicon).
Lesson 2: Streamline the model portfolio and reduce complexity and overlap to help scale what works
- CMS recognizes that providers participate in multiple reimbursement models, and that it’s not ideal when two different programs offer conflicting incentives.
- They also saw that providers need to employ different people and processes depending on the revenue model, which made it inconvenient when the models inevitably changed every year or two.
- It’s nice of CMS to recognize these difficulties. When it comes down to it, CMS has to design models robust enough to accommodate thousands of providers and millions of patients — the models are going to be complex and overlapping.
Lesson 3: Tools to support transformation in care delivery can assist providers in assuming financial risk
- In line with the goal to embed health equity in every model, CMS wants to make sure they support the providers that opt into Innovation Center models. That means CMS providing data directly and offering subsidies to providers who want to invest in better data tools.
Lesson 4: Design of models may not consistently ensure broad provider participation
- Because Innovation Center models have been opt-in, the providers who sign up are either (a) good at math, and confident they will profit; (b) strong appetite for risk and/or care transformation; (c) both. This further reinforces the dynamic where richer and whiter patient populations disproportionately benefit.
- To combat this, the Innovation Center is going to try to make their models more attractive to risk-averse providers (probably via guaranteed care management dollars). And in a more brute-force move, they will also try mandatory participation.
Lesson 5: Complexity of financial benchmarks have undermined model effectiveness
- This is a remarkably-neutral reference to the MA Money Machine, and how a few providers are profiting wildly from the current risk-adjustment rules.
- The Innovation Center will do their best to make sure new models don’t have egregious financial loopholes. And they’d better! Don Berwick said in a private Q&A that he thinks the #1 application of AI and machine learning in healthcare is risk score gaming.
Lesson 6: Models should encourage lasting care delivery transformation
- If providers go back to business-as-usual as soon as a model ends, then how successful was the model, really?
How much does any of this matter? I think it matters, and here’s why:
- With the rules as they are today, we the taxpayers will keep spending more money on healthcare every year.
- I don’t believe the political will exists to pass a radically new healthcare law.
- Therefore, the best shot the US has for containing healthcare costs is via the Innovation Center’s authority within the ACA to test new payment models, and keep the ones that work.
I wish them lots of luck.
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