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March 24, 2014

CMS Issues RFI on Transforming Medical Practices and Value-Based Payment

The Centers for Medicare and Medicaid Services (CMS) is soliciting public commentary on the optimal ways to transform medical practices and prepare them for value-based purchasing. Entitled Request for Information: Transforming Clinical Practices, the RFI seeks responses from Clinicians, Health Plans and a variety of other associations about large scale transformation of clinician practices, to generate better care and better health at lower costs.

According to CMS, the feedback from the RFI may be used to develop future Requests for Proposals and test new payment and service delivery models to assist practices in their work to prepare for participation in new value-based payment programs. CMS divides the RFI into four sections, and includes 35 different questions. We've briefly highlighted some of the questions; click here for the full list (page 3).

  1. Practice Transformation Strategies, Resources and Opportunities
  • What key areas of practice transformation require attention?
  • What does a transformed clinical practice look like?
  • What should CMS consider if it were to organize a program of technical assistance to support the transformation of clinician practices and to prepare for effective participation in value based payment?
  • What should CMS consider to ensure local "on- the-ground" support to practices?
  • What would ensure that groups of solo, small practices and rural providers have the opportunity to actively participate in practice transformation?
  • What general quality improvement strategies should practices employ to build a sustainable continuous quality improvement program?
  • How are practices using Health Information Technology (HIT) and Electronic Medical Record (EMR) technology to improve patient health outcomes?
  • How are practices addressing race, ethnic, primary language, and disability status health disparities in their work to improve patient health outcomes?

B. Challenges and lessons learned in Practice Transformation engagement

  • What are the most significant clinician challenges and lessons learned related to transforming a practice and what solutions have been successful in addressing these issues?
  • How can physician/clinician affinity groups be leveraged to strengthen the care process and for improve patient outcomes?
  • What challenges that have not been successfully addressed to date need to be addressed to achieve desired outcomes in health, healthcare, and more affordable care?
  • What information privacy challenges are anticipated or have been experienced in the transformation of practices?

C. Engagement, Partnership and Continuous Learning in Practice Transformation

  • What should CMS consider when spreading innovations through learning systems, working with private payors and states in practice transformation?
  • What would motivate clinicians to participate in any potential future initiatives relating to practice transformation and value-based purchasing?
  • What would motivate new partners to enter the field of practice transformation as a prime contractor, subcontractor, or consultant?
  • Are there other successful mechanisms that support engagement in practice transformation that could be considered?

D. Current Engagement in CMS Models

  • What is your current relationship with CMS initiatives related to practice transformation
  • In your transformation efforts, have you seen any program integrity issues and what strategies did you use to assure that transformation efforts did not foster integrity problems? Did you actively design strategies to mitigate any such issues? What were the mitigation strategies?
  • How could CMS possibly use patient satisfaction surveys or report cards regarding practice transformation?

To submit responses, all comments are requested in the online format by 11:59 pm EDT on April 8, 2014. Click here to submit comments.

We hope that the RFIs lead to clarity for the healthcare community. With 35 questions in the RFI, it seems as though CMS has many questions about how to make this a smooth process.

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With the cost of medical care continue to rise faster than the GNP the general policy has been in an effort to lower costs that we should follow the lead of insurers, hospital administrators, and policy wonks. This associate with elimination of fee-for-service and increasing percentage of doctors now on salary, and this coupled with the elimination of the free clinics the free hospital are associated with increasing medical care costs of decreasing the quality of care. These all are occurring while the doctors incomes have been falling.
What sense is there to encourage doctors to work less time by encouraging a 40 hour work week or less. This then associated with the policy of giving money to the insurance companies to hold for those who have had insurance in the past or who have not had medical insurance in the past. This does not seem to be "rocket science" and seems to be associated with a progressive decline in medical care based upon the expectations of all including the young doctors.

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