In the more than 1,300 comments submitted to the Centers for Medicare & Medicaid Services (CMS) on the Part B Drug Payment Model, a wide range of organizations raised concern with the unprecedented scope of the proposal. Comments focused both on how the scale of the experiment and the process CMS used to develop it mark a radical departure from their previous work under the Center for Medicare & Medicaid Innovation (CMMI). (We covered what CMMI is here.)
Last week, a new report released by Avalere Health took a closer look at the evolution of CMMI since its creation. The paper confirmed the Part B proposal marks a significant departure from prior models due to its broad scale and requirement for mandatory participation. “CMMI’s approach to introducing changes to the Medicare and Medicaid programs using its unique regulatory authority rather than a legislative process represents a significant evolution in how HHS is executing its authority, which warrants close attention,” the paper explains, also reiterating the critical importance of measurement and evaluation in developing models.
Many across the health care landscape have raised concerns about this new and concerning approach. The American Medical Association said in its comments, “Given the scale of this model, the patient protections are threadbare and do not provide for active monitoring to assess negative patient outcomes in real time. This underscores that the model as constructed is too large with too many unknown variables.” The National Alliance on Mental Illness stated their concern that Phase 2 could impose one-size-fits-all coverage policies in Medicare, a topic we explored in this case study.
The American Cancer Society added, “We are particularly concerned that the project’s breadth and scope goes well beyond the standard size of a demonstration project and could directly impact a cancer patient’s access to care.”
Learn more about the proposed changes at PhRMA.org/PartB.