2018 is shaping up to be the year for designing and proposing integrated care models for testing by the Centers for Medicare & Medicaid Services (CMS). There are three major factors driving this trend:
Physician-Focused Payment Model Technical Advisory Committee (PTAC).
Request for Information (RFI) by the Centers for Medicare and Medicaid Services Innovation Center.
Perception that the train is leaving the station.
With further examination of these three factors, it becomes clearer how closely tied they are to one another.
PTAC
The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) created new pathways for the Medicare program to pay physicians for the care they provide. MACRA also created incentives for physicians to participate in Alternative Payment Models (APMs), including the development of physician-focused payment models (PFPMs). To accomplish that goal, MACRA created PTAC to evaluate and recommend to the Secretary of the Department of Health and Human Services (HHS) proposals for PFPMs submitted by individuals and stakeholder groups. The Secretary is required by MACRA to establish criteria for PFPMs and to respond to the recommendations of PTAC.
The PTAC completed its third public meeting and its first year of operations in December 2017. Now, the body seems to have arrived at a fully operational state and is sending out the message to “bring your integrated care models to them for review.” At the December 2017 meeting, PTAC voted to recommend a proposal for an Incident ESRD Clinical Episode Payment Model submitted by the Renal Physicians Association (RPA). ASN is currently finalizing a proposal for a comprehensive kidney care model spanning late CKD, ESRD, transplant, and posttransplant that it hopes to submit to the PTAC in 2018.
Information sought by CMS Innovation Center
In late 2017, the CMS Innovation Center issued an RFI seeking feedback on new directions to promote patient-centered care, and test market-driven reforms, as well as PFPMs. ASN answered the call for feedback with a detailed outline of its proposal for a comprehensive kidney care model. This is the same model, described above, under development for the PTAC. This two-tiered approach follows the pathway laid out under MACRA. First, the PTAC will evaluate and recommend models for testing it deems in line with criteria outlined in the MACRA final rule issued in 2016. If the model passes the PTAC and the office of the HHS Secretary, then it is forwarded to the CMS Innovation Center for the actual testing of the model. The RFI by the CMS Innovation Center appears designed to keep this process moving along a forward trajectory.
The train is leaving the station
Under the Quality Payment Program (QPP), which is in and of itself a model that is still evolving, created by MACRA, it is open season for integrated care model development.
With the PTAC having successfully navigated its first year and entering its second and the CMS Innovation Center joining the call for models, the testing grounds appear primed. ASN believes the mechanisms are in place and the conditions are right for nephrology, and other specialties in their own space, to advocate for a nephrology-led integrated care model.
