American College of Rheumatology responds to CMS Innovation Center request for information
ATLANTA – The American College of Rheumatology (ACR) urged the Centers for Medicare and Medicaid Services (CMS) to remove barriers that make it difficult for subspecialists and providers in small practices to participate in alternative payment models (APMs) in a comments letter submitted in response to the Center for Medicare and Medicaid Services: Innovation Center New Direction Request for Information.
"We believe the more rheumatologists who are able to participate in APMs, the more time they can spend with their patients managing their complex care needs, which will ultimately improve care quality and lower costs," said David Daikh, MD, PhD, President of the American College of Rheumatology. "To that end, we have recommended specific changes that would decrease the burden of financial risk on small practices and increase specialists' participation in advanced APMs, specifically physician-focused specialty models and prescription drug models."
Noting that a well-crafted, physician-focused APM must be flexible to be viable and attractive to specialists – including rheumatologists – who practice in a diverse range of settings across the country, the ACR put forth the following recommendations:
- Lower the payment and patient count thresholds used to determine 'qualifying participant' status from 25 to 15 percent and 20 to 10 percent, respectively. This will allow more rheumatologists, many of whom run small practices, to take part in in physician-focused APMs while reducing their financial risk of participation.
- Allow the set-up cost of physician-focused APMs, including the cost of health record upgrades and employee training, to serve as the financial risk, at least on an interim basis. The current risk criteria makes it difficult for many physician-focused APMs to achieve "advanced" status which serves as an additional barrier to getting more rheumatologists to participate.
- Ensure that future APMs provide appropriate reimbursement for services provided by cognitive specialists. Services such as non-face-to-face care and chronic disease care coordination are critically important, yet undervalued in the current system. Future APMs should appropriately reimburse for these services, which help prevent costly and unnecessary procedures while lowering overall costs.
The ACR is also currently working to develop its own rheumatoid arthritis-specific APM that will address these concerns and serve as a template for future payment reform. This approach, which is based on flexibility in multiple domains, will encourage more rheumatologists to engage with physician-focused APMs and enhance the uptake of value-based reforms throughout the U.S. healthcare system.
"As CMS continues to forge a new direction for CMMI, we encourage transparency throughout the process and strongly suggest any proposed new payment models go through the full public rule making process," concluded Daikh.
About the American College of Rheumatology
The American College of Rheumatology (ACR) is the nation's leading advocacy organization for the rheumatology care community, representing more than 9,500 rheumatologists and rheumatology health professionals. As an ethically driven, professional membership organization committed to improving healthcare for Americans living with rheumatic diseases, the ACR advocates for high-quality, high-value policies and reforms that will ensure safe, effective, affordable and accessible rheumatology care.