CMS Seeks Comment on Future of the Innovation Center through “New Direction” RFI

On September 20, 2017, the CMS Innovation Center issued a Request for Information (RFI) seeking feedback on the future direction for the Center’s efforts. The RFI is available here.


Congress created the Innovation Center in 2010 to test new approaches and models to pay for and deliver healthcare. In an accompanying op-ed published in the Wall Street Journalon September 19, 2017, CMS Administrator Seema Verma announced the release of the RFI and that CMS is  considering new directions to determine what is and is not working at the Innovation Center.

The RFI is consistent with language in the recently released proposed rule revising mandatory bundled payment models released in mid-August by declaring a clear preference for voluntary over mandatory payment models. This signals a different direction from the previous Administration, which implemented the mandatory Comprehensive Joint Replacement Model (CJR), finalized regulations for mandatory cardiac episode payment models and proposed a mandatory payment model for Part B drugs (never finalized).

Guiding Principles

In the RFI CMS indicates that they will approach new model design through the following guiding principles:

  • Choice and competition in the market
  • Provider Choice and Incentives
  • Patient-centered care
  • Benefit design and price transparency
  • Transparent model design and evaluation
  • Small Scale Testing

Innovation Center Focus Areas

The Innovation Center is interested in testing models in the following eight focus areas:

  • Increased participation in Advanced Alternative Payment Models (APMs)
  • Consumer-Directed Care & Market-Based Innovation Models
  • Physician Specialty Models
  • Prescription Drug Models
  • Medicare Advantage (MA) Innovation Models
  • State-Based and Local Innovation, including Medicaid-focused Models
  • Mental and Behavioral Health Models
  • Program Integrity

RFI Questions

CMS posed the following questions in the RFI. They are seeking evidence-based, empirical, and actionable evidence and are requesting respondents to cite this evidence in the feedback they submit to CMS.

  • Do you have comments on the guiding principles or focus areas?
  • What model designs should the Innovation Center consider that are consistent with the guiding principles?
  • Do you have suggestions on the structure, approach, and design of potential models? Please also identify potential challenges or risks associated with any of these suggested models.
  • What options might exist beyond FFS and MA for paying for care delivery that incorporate price sensitivity and a consumer driven or directed focus and might be tested as a model and alternative to FFS and MA?
  • How can CMS further engage beneficiaries in development of these models and/or participate in new models?
  • Are there payment waivers that CMS should consider as necessary to help healthcare providers innovate care delivery as part of a model test?
  • Are there any other comments or suggestions related to the future direction of the Innovation Center?

Comments can be submitted online here or by email to through 11:59 p.m. EST November 20, 2017.

For more information on the CMS Quality Payment Program visit the McDermottPlus MACRA Resource Center or contact Sheila Madhani at 202-204-1459,