The Physician Focused Payment Model Technical Advisory Committee (TAC) met for the first time on Monday, February 1, 2016 in Washington, DC. Established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), this committee is tasked with providing comments and recommendations to the Secretary of Health and Human Services on physician payment models.
The Committee includes 11 members who are nationally recognized for their expertise in physician-focused payment models and related delivery of care. With authority delegated by the Secretary, the Assistant Secretary for Planning and Evaluation, Richard G. Frank, PhD recently appointed Jeffrey Bailet, MD, as the Chairperson of the Committee and Elizabeth Mitchell as the Vice Chairperson of the Committee. A complete list of committee members and brief biographies can be found here.
During this first meeting, the committee presented a proposed framework for the proposal submission process, there was an opportunity for members of the public to make comments, and representatives from the Center for Medicare & Medicaid Innovation (CMMI) made a presentation on the process for model development within CMMI.
Proposed Framework for the Proposal Submission Process
The basic steps of the proposal process were described as:
- Step 1: Stakeholder submission
- Step 2: Preparation for review
- Step 3: Committee review for recommendation
- Step 4: Secretarial review
The committee indicated that they would like input from the public on the entire process. Under its mandate, the Committee shall explain whether submitted models meet criteria established by the Secretary for physician-focused payment models and the rationale for their comments and recommendations. While the criteria has not yet been established, Committee member Harold Miller did indicate that he believes that the following type of information should be included in a proposal:
- What is the nature of the improvement on care?
- What is the barrier the proposal is trying to overcome?
- What is the nature of the accountability that the physician will be taking?
- If it is a specialty specific model, how will the specialist work with other providers?
In discussing how they envision this process working members of the committee also stated that they were committed to a very open and transparent process, they wanted to hear from stakeholders throughout the process and finally that they wanted to hear not just from physicians but from others that would be impacted by these models (i.e. payors, other providers, patients).
Theme of Public Comments
Members of the public attending in person and participating on the phone were given an opportunity to provide comments. The committee heard from over a dozen commenters. Almost all of the commenters were representatives from physician specialty organizations. Many of the representatives form physician specialty organizations spoke for the need for specialty specific proposals while the representative from the American Academy of Family Physicians (AAFP) urged the committee to focus on general models. Other issues raised by commenters were:
- There are certain costs and outcomes that are out of a physician’s control, physicians should not be held accountable for these factors
- Flexibility is key important in design development
- The physician-patient relationship must be preserved
- The burden of technology adoption should be recognized
A representative from the American Society for Radiation Oncology (ASTRO) was the only commenter who spoke about specific models under development. ASTRO is developing a model for bone metastasis and another model for early stage breast cancer. While they did not provide specifics on the model they did share the guiding principles they have developed and are applying to this effort. These principles are:
- Define episodes of care where there are clear guidelines
- Address over and under utilization of care
- Seek to preserve the flexibility so the doctor and patient can continue to choose the care
- Two pronged quality approach: standards (via accreditation) and disease specific (via quality measures
The meeting concluded with a presentation form representatives on the model development process at CMMI. The plan is that at every that at every stage of the model development process, CMMI will consider if the model meets the criteria for a MACRA-eligible alternative payment model (APM).
While CMMI representatives did not directly address the issue of a preference for specialty versus general models, they did state that due to the significant resources involved in developing and deploying a model, they look for models that can have a larger impact.
The PPT presentations can be found here.
More information on the committee can be found here.