July 28, 2023
The Alliance signed on to a letter with 20+ other health/medial associations to the Centers for Medicare and Medicaid Innovation (CMMI) requesting an extension to comment on its Request for Information seeking stakeholder input regarding the design of future episode-based payment models. The RFI was published on July 18 - just days after the draft 2024 Medicare Physician Fee Schedule and Outpatient Prospective Payment System proposed rules were released for comment.
The RFI required comments within 30 days for this large and important payment issue – which we and others did not feel was sufficient time to vet within our various memberships to consolidate and provide substantive feedback. CMMI said it could not extend comment period but will provide additional opportunities to comment in rulemaking. In issuing the RFI, CMS is looking to address the inefficiencies in traditional Medicare fee-for-service, where providers are paid for each item or service, which may drive volume over value and fragment care. CMS indicated that the Innovation Center intends to design, implement, and evaluate future episode-based payment models with a focus on five strategic objectives, including advancing health equity and driving accountable care.

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