Thoughts for Senate Finance Committee re: Chronic Care Management Innovation Center (CCMIC), Rapid Learning Network (RLN) and payments
Posted on June 13, 2009, 1:57 pm, by Ken Coburn, MD, MPH.
- Programs which are diverse, creative and innovative should be invited to participate in the CCMIC and RLN, but they should also be carefully specified – i.e., program elements, processes, protocols and operational standards should be clearly described and documented
- Flexibility with regard to changes to programs during their study periods is key, but these also must be carefully documented
- A public database of the operational specifications of programs and changes to them over time should be developed
i. Ideally a reliable measure of a program’s own adherence to these operational specifications should be included in such a database as well
- Open access (with appropriate privacy and usage safeguards) to CMS claims data should be made available in as timely and inexpensive a manner as feasible to all participating sites and other interested researchers who meet a minimum standard of qualification for the competent use of such data; MORE analysis of these programs by independent and qualified health services researchers is essential both for transparency and to accelerate innovation
- Base payments for program services are best provided on a per person per month (PPPM) basis negotiated between care coordination provider and CMS (either on a defined population or per ‘enrolled’ participant)
- Requirement for immediate budget neutrality should be relaxed and applied only after program has had an opportunity to refine its model with adequate time and data (e.g., 4 to 5 years)
i. To safeguard against excessive losses to Medicare, thresholds could be established beyond which programs could be discontinued early (e.g., 2 to 3 years)
- Bonus payments in addition to base PPPM – 80% of net savings to care coordination provider (20% to CMS) beyond a minimum savings threshold (2%) for evidence of quality improvement and/or improved health outcomes; modeled after the approach used in the CMS Physician Group Practice Demonstration
- Payment flexibility and incentive innovation – allow provider of care coordination to split none, either, or both base PPPM payments and earned bonus payments with other providers of health care services and, perhaps, even Medicare beneficiaries themselves
