On June 3, 2020, the Centers for Medicare and Medicaid Services Innovation Center (CMMI) released a blog post and comprehensive table detailing new flexibilities and adjustments to CMMI models intending to address the current COVID-19 health emergency. The announcement comes after much speculation among CMMI model participants as to how 2020, and the COVID-19 health emergency would be treated.
Recognizing that the COVID-19 emergency presents unprecedented challenges that require increased flexibility, CMMI has made changes that it states are designed to continue sufficient financial incentives, minimize reporting burdens, decrease risk to model participants, and limit delays in new model implementation. The full table of CMMI flexibilities can be accessed here, and the flexibilities fall into three categories: financial methodology changes, quality reporting changes, and model timeline changes. Overall, the updates give providers flexibility to put risk on hold (though it must include upside and downside risk), and push out the time frames on several models to account for the disruption. See below for specific examples of changes made.
The proposed changes come at a critical time, as health care providers are slowly beginning the path to recovery while at the same time preparing for potential COVID-19 resurgence in the fall. The COVID-19 health emergency has tested alternative payment models and exposed their weaknesses. Many providers are struggling to stay solvent with the suspension of non-emergent procedures, a sudden shift to a telehealth focused care delivery model, and a population unwilling to seek care for fear of contracting COVID-19, and their ability to bear risk for the care of patients up in the air. Furthermore, providers are being forced to explore new pathways to reach their patients, in order to meet quality metrics that may not make sense in the current environment. Commercial payers are also trying to determine how to address 2020 performance in their alternative payment model contracts, whether through the use of prior year performance results, revised quality metrics, or program suspension. Many will likely follow the path of CMMI now that it has released its proposal. As providers decide how they will navigate their participation in CMMI models, and whether they can continue to participate in light of the current environment, so too will commercial payers be forced to renegotiate their arrangements with providers.
Some specific examples of changes in the chart released include:
CMMI is scheduling model specific stakeholder calls over the coming weeks to allow stakeholders to ask questions.
For more information on these flexibilities, please contact your Foley relationship partner or the Foley colleagues listed below. For additional web-based resources available to assist you in monitoring the spread of the coronavirus on a global basis, you may wish to visit the websites of the CDC and the World Health Organization.
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