Today, CMS released its strategy for the CMS Innovation Center (the “Strategy”) in a White Paper, Innovation Center Strategy Refresh. This Strategy and the connection to broader CMS priorities was outlined by CMS Administrator Brooks-LaSure and CMS Innovation Center Director, Liz Fowler, in a webinar and is intended as a blueprint for the next 10 years.  While the Innovation Center’s overarching goal continues to be expansion of successful models that reduce program costs and improve quality and outcomes for Medicare and Medicaid beneficiaries, CMS highlights five strategic objectives: Drive Accountable Care, Advance Health Equity, Support Innovation, Address Affordability, and Partner to Achieve System Transformation and created a new vision: “A health system that achieves equitable outcomes through high-quality, affordable, and person-centered care.”

What’s New?

In putting forth this new vision and strategy, CMS notes that they have reviewed 10 years of experience with the Innovation Center and consulted external research and experts to inform this strategy refresh.  Some of the key lessons learned signal areas of change:

  • Ensure health equity is embedded in every model;
  • Streamline the model portfolio and reduce complexity and overlap;
  • Use of tools to support transformation in care delivery, which can assist providers in assuming financial risk;
  • Design of models may not consistently ensure broad provider participation;
  • Complexity of financial benchmarks have undermined model effectiveness; and
  • Models should encourage lasting care delivery transformation.

In an effort to focus on equity, affordability and “person-centered care” and to address some of these key lessons, the Strategy notes that CMS will launch more Medicaid-focused models.  In addition, CMS will support all beneficiaries having access to providers engaged in care transformation by addressing issues such as implicit bias in model design, implementation, and evaluation.  CMS intends to focus on reducing selection bias by improving model design (e.g., benchmarking, risk adjustment, and care transformation supports) to ensure participation from a diverse group of providers—including those that care for underserved communities.

CMS states that it will make model parameters, requirements, and other critical details more transparent and easier to understand. Further, they intend to make available timely, actionable data to support decision-making at point of care and encourage and support use of interoperability standards for the exchange of health data.  Similarly, CMS intends to make available actionable data, learning collaboratives, and payment and regulatory flexibilities to participants, especially those caring for the underserved.

What’s Next?

CMS noted that, in the future, there will be fewer models, and that the models will have less overlap and more clarity regarding attributes.  They will be focusing more attention on health equity, including addressing barriers to participation in rural and underserved areas and supporting participation by a broader set of providers, including safety net providers.  While CMS stated that there is no decision to end models early, the Strategy will guide revisions to existing models, including possible modifications to address social determinants of health.

CMS stressed that they will focus on transparency, communication and stakeholder outreach.  To that end, CMS plans to hold listening sessions starting in November.

We encourage participants and potential participants in CMMI models to engage with CMS to provide input regarding your experiences, recommended changes to existing models, and any questions you have regarding CMMI strategic priorities.

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Photo of Jodi G. Daniel Jodi G. Daniel

Jodi Daniel is a partner in Crowell & Moring’s Health Care Group and a member of the group’s Steering Committee. She is also a director at C&M International (CMI), an international policy and regulatory affairs consulting firm affiliated with Crowell & Moring. She…

Jodi Daniel is a partner in Crowell & Moring’s Health Care Group and a member of the group’s Steering Committee. She is also a director at C&M International (CMI), an international policy and regulatory affairs consulting firm affiliated with Crowell & Moring. She leads the firm’s Digital Health Practice and provides strategic, legal, and policy advice to all types of health care and technology clients navigating the dynamic regulatory environment related to technology in the health care sector to help them achieve their business goals. Jodi is a contributor to the Uniform Law Commission Telehealth Committee, which drafts and proposes uniform state laws related to telehealth services, including the definition of telehealth, formation of the doctor-patient relationship via telehealth, creation of a registry for out-of-state physicians, insurance coverage and payment parity, and administrative barriers to entity formation.

Photo of Troy A. Barsky Troy A. Barsky

Troy Barsky is a partner in Crowell & Moring’s Washington, D.C. office, and serves as a member of the firm’s Health Care Group Steering Committee where he focuses on health care fraud and abuse, and Medicare and Medicaid law and policy. Troy counsels…

Troy Barsky is a partner in Crowell & Moring’s Washington, D.C. office, and serves as a member of the firm’s Health Care Group Steering Committee where he focuses on health care fraud and abuse, and Medicare and Medicaid law and policy. Troy counsels all types of health care entities, including hospitals, group practices, and health plans on the physician self-referral law (Stark Law) and the Anti-Kickback Statute, innovative healthcare delivery models, such as Accountable Care Organizations (ACOs), and Medicare & Medicaid payment and coverage policy. He also defends clients seeking resolution of government health care program overpayment issues or fraud and abuse matters through self-disclosures and negotiated settlements with the U.S. Department of Justice, U.S. Health & Human Services Office of the Inspector General and the Centers for Medicare & Medicaid Services (CMS).

Photo of Janet Walker Janet Walker

Janet Walker is a senior counsel in the Washington D.C. office and member of the Health Care Group. She has a deep understanding of federal and state healthcare law and policy as it relates to value-based care and population health initiatives.