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Federal Policy Updates

For state specific policy head to State Policy Updates

Coalition Letter on Improving Transparency for Innovation Center Models

March 26, 2019

March 26, 2019


The Honorable Seema Verma
Administrator
Centers for Medicare & Medicaid Services
US Department of Health & Human Services
Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201

Adam Boehler
Deputy Administrator
Director of the Center for Medicare & Medicaid Innovation
Centers for Medicare & Medicaid Services
US Department of Health & Human Services
Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201

Re: Improving Transparency for Innovation Center Models

Dear Administrator Verma and Deputy Administrator Boehler:

The undersigned organizations write to encourage the CMS Center for Medicare & Medicaid Innovation (Innovation Center) to continue to improve transparency and stability as you develop a successful portfolio of payment models. While we appreciate steps the agency has taken, such as hosting stakeholder roundtable discussions to gather input, we ask that the Innovation Center move to a more methodical and public process for releasing and updating payment models.
Like you, our organizations and the members they represent are committed to the move to alternative payment models (APMs), including those with an emphasis on performance-based risk. We agree that many provider groups of various sizes and composition across the country are prepared to make the leap to greater levels of financial and clinical accountability to improve the health of America’s seniors. Provider organizations that have taken the first step toward two-sided risk models have successfully reduced costs and improved care for patients.1 We are excited to continue to work with the Innovation Center to pursue new models, many of which will feature increasing levels of financial risk and reward. We are confident that this is the right direction to create a sustainable healthcare delivery system for the future.

To accelerate participation in APMs and the move to performance-based risk, we request that the Innovation Center continue to take steps to improve transparency and stability. As you know, responsibly moving to higher levels of financial risk requires a steady and predictable payment environment. This allows organizations to plan their budgets and care coordination activities and to predict how they will fare under any given model. Creating a clarity and stability for model design will encourage provider organizations to move to higher levels of risk and reward more quickly.

Specifically, we ask that you move Innovation Center models to a public process that would allow an opportunity for stakeholder comment on all model design elements prior to finalizing the model. We also request that model changes be made and communicated in a clear and public manner. To achieve this goal, we recommend establishing a process similar to those used for other programs, such as the Medicare Advantage Rate Notice and Call Letter and the State Medicaid Director Letters. In these programs, certain updates and policy changes are communicated publicly with some opportunity for stakeholder feedback, but without the formality of notice and comment rulemaking. In contrast, in the current Innovation Center models, changes are often communicated through contract amendments – sometimes in the middle of a performance year. As part of this new process, we request that the Innovation Center refrain from making mid-year changes, which have a significant programmatic or financial impact on model participants, and therefore create tremendous destabilization given the many decisions model participants make based on their unique circumstances and projections going into the performance year (unless such changes are optional or voluntary for program participants).

We believe that public communication of model design elements and eliminating mandatory mid-year changes would improve providers’ ability to evaluate and compare options while still allowing the Innovation Center to be nimble and flexible, consistent with its mission. Affording stakeholders an opportunity to provide feedback will strengthen the model portfolio over the long term and create stability and predictability that supports moving away from fee-for-service and fosters the movement to higher levels of risk and reward. We are committed to this transition and look forward to working with you to continue to advance this movement. Together, we can develop delivery and payment systems that improve the nation’s health and fiscal outlook.

Sincerely,

AMGA
Association of American Medical Colleges
Health Care Transformation Task Force
Medical Group Management Association
National Association of ACOs
National Coalition on Health Care
Next Generation ACO Coalition
Patient-Centered Primary Care Collaborative
Premier

1 NORC, First Annual Report, Next Generation Accountable Care Organization (NGACO) Model Evaluation (August 2018), available at https://innovation.cms.gov/Files/reports/nextgenaco-firstannrpt.pdf.

Coalition Letter to Align 42 CFR Part 2 With HIPAA to Allow Appropriate Access to Patient Information That is Essential for Providing Whole-Person Care

March 1, 2019

“We applaud this effort to expand the care team’s ability to coordinate appropriately and deliver high-value, accessible care – as well as steps to enhance trust between patient and clinicians. If behavioral health and substance use disorder treatment are going to be effectively integrated into a team-based system empowering patients and their primary care clinicians to manage both physical and behavioral health, we need to move forward on passage to allow better sharing of health information for persons in these treatment programs.” -- Ann Greiner, President and CEO, Patient- Centered Primary Care Collaborative

PARTNERSHIP TO AMEND 42 CFR PART 2

A COALITION OF NEARLY 50 HEALTH CARE STAKEHOLDERS COMMITTED TO ALIGNING 42 CFR PART 2 (PART 2) WITH HIPAA FOR TREATMENT, PAYMENT, AND HEALTH CARE OPERATIONS (TPO) TO ALLOW APPROPRIATE ACCESS TO PATIENT INFORMATION THAT IS ESSENTIAL FOR PROVIDING WHOLE-PERSON CARE.

March 1, 2019
The Honorable Lamar Alexander, Chairman
Senate Committee on Health, Education, Labor, and Pensions
428 Dirksen Senate Office Building
Washington, DC 20510

Dear Chairman Alexander:

On behalf of the Partnership to Amend 42 CFR Part 2 (Partnership), I appreciate the opportunity to respond to your request for recommendations to help address America’s rising health care costs.

The Partnership is a coalition of nearly 50 national health care organizations representing a range of stakeholders, including patients, clinicians, hospitals, biopharmaceutical companies, pharmacists, electronic health record (EHR) vendors, and insurance providers. The Partnership is committed to aligning 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO) to allow appropriate access to patient information that is essential for providing whole-person care while protecting patient privacy. See attached position paper for more information and a full list of Partnership members.

As you address the rising health care costs in this country, modernizing Part 2 – by aligning it with HIPAA for TPO – will reduce barriers to innovation and coordinated care, thereby contributing to decreased health care costs, particularly for substance use disorders (SUD).

Part 2, Federal Confidentiality of Substance Use Disorder Patient Records, sets requirements limiting the use and disclosure of patients’ substance use records from certain substance use treatment programs. Patients must submit written consent prior to the disclosure of their SUD record. Obtaining multiple consents from the patient is challenging and creates barriers to whole-person, integrated approaches to care, which are part of our current health care framework. In situations where the patient does not give consent, Part 2 regulations may lead to a doctor treating a patient and writing prescriptions for opioid pain medication for that individual without knowing the person has a SUD. Separation of a patient’s addiction record from the rest of that person’s medical record creates obstacles and prevents patients from receiving safe, effective, high quality substance use treatment and coordinated care.

Part 2 was created to reduce stigma associated with SUDs and encourage people to seek treatment without fear of prosecution by law enforcement. These important goals can still be addressed while modernizing the regulations. Part 2 is not compatible with the way health care is currently delivered; and in order to bring the regulations in line with 21st Century health care, Part 2 needs to harmonize with HIPAA to allow for the transmission of SUD records without written consent for TPO. This will promote integrated care and enhance patient safety, protect against prosecution by law enforcement, and provide health care professionals with one federal privacy standard for all of medicine.

Health care is constantly evolving, and our coalition members are able to use technology and data to improve care delivery and outcomes and reduce costs for the toughest chronic diseases, with the exception of SUDs. The ability to share patients’ entire medical records by aligning Part 2 with HIPAA for TPO will lead to better health care, reduced costs, and improved safety.

Last year, the House of Representatives passed the Overdose Prevention and Patient Safety (OPPS) Act, H.R. 6082, by an overwhelmingly bipartisan vote of 357-57. This bill would align Part 2 with HIPAA for TPO and strengthen protections against the use of addiction records in criminal, civil, or administrative proceedings. This bill further amplifies patient protections by incorporating antidiscrimination language, significantly enhanced penalties for any breach of a person’s substance use record, and breach notification requirements. Senators Shelley Moore Capito (R-WV) and Joe Manchin (D-WV) have championed this issue in the Senate, and they plan to introduce the language from H.R. 6082 this year. The Administration has also indicated that it will be addressing Part 2 as the last phase of the Department of Health and Human Services’ (HHS) “regulatory sprint”.

Thank you for considering our recommendation. If you have any questions, please contact me at (202) 449-7660 or klein@abhw.org.
Sincerely,

Rebecca Murow Klein, Chair
Partnership to Amend 42 CFR Part 2
Attachment: Partnership to Amend 42 CFR Part 2

Academy of Managed Care Pharmacy ∙ Alliance of Community Health Plans ∙ American Association on Health and Disability ∙ American Dance Therapy Association ∙ American Health Information Management Association ∙ American Hospital Association ∙ American Psychiatric Association ∙ American Society of Addiction Medicine ∙ American Society of Anesthesiologists ∙ America’s Essential Hospitals ∙ America’s Health Insurance Plans ∙ AMGA ∙ Association for Ambulatory Behavioral Healthcare ∙ Association for Behavioral Health and Wellness ∙ Association for Community Affiliated Plans ∙ Association of Clinicians for the Underserved ∙ Blue Cross Blue Shield Association ∙ The Catholic Health Association of the United States ∙ Centerstone ∙ College of Healthcare Information Management Executives ∙ Confidentiality Coalition ∙ Corporation for Supportive Housing ∙ Employee Assistance Professionals Association ∙ Global Alliance for Behavioral Health and Social Justice ∙ Hazelden Betty Ford Foundation ∙ Health Innovation Alliance ∙ Healthcare Leadership Council ∙ InfoMC ∙ The Joint Commission ∙ The Kennedy Forum ∙ Medicaid Health Plans of America ∙ Mental Health America ∙ National Alliance on Mental Illness ∙ National Association for Behavioral Healthcare ∙ National Association for Rural Mental Health ∙ National Association of ACOs ∙ National Association of Addiction Treatment Providers ∙ National Association of Counties ∙ National Association of County Behavioral Health and Development Disability Directors ∙ National Association of State Mental Health Program Directors ∙ National Rural Health Association ∙ Netsmart ∙ OCHIN ∙ Otsuka America Pharmaceutical, Inc. ∙ Patient-Centered Primary Care Collaborative ∙ Pharmaceutical Care Management Association ∙ Premier Healthcare Alliance ∙ Smiths Medical ∙ Strategic Health Information Exchange Collaborative

Coalition Letter on Rising Health Costs and Value-Based Insurance Design

March 1, 2019

March 1, 2019

The Honorable Lamar Alexander
Chairman
Committee on Health, Education, Labor, and Pensions
428 Dirksen Senate Office Building
Washington, DC 20510

The Honorable Patty Murray
Ranking Member
Committee on Health, Education, Labor, and Pensions
428 Dirksen Senate Office Building
​Washington, DC 20510

Dear Chairman Alexander and Ranking Member Murray:

The Smarter Health Care Coalition (Coalition) appreciates the opportunity to respond to your recent letter seeking specific recommendations to address rising health care costs in the United States and steps that Congress and the Trump Administration should take to address this important issue. In doing so, we urge you to consider policy solutions that increase access to high-value health care services and medications consistent with the principles of value-based insurance design (V-BID).

The Coalition represents a broad-based, diverse group of health care stakeholders, including consumer groups, health plans, life science companies, employers, provider organizations, and academic centers. The Coalition is squarely focused on achieving “smarter health care” by removing barriers to clinically-nuanced health care services and medications. Our goal is to better align health care spending with value, improve the patient experience, and lower health care costs by supporting innovative benefit design that encourages the use of high-value care, and discourages the use of low-value care.

Overall, we offer the following recommendations consistent with the principles of V-BID to address rising health care costs in the U.S.:
1) Increase Access to High-Value Care for Chronically Ill Patients with Health Savings Account (HSA)-qualified high deductible health plans (HDHPs). Ensure that chronically ill individuals in HSA-HDHPs are not prohibited from having pre-deductible access to critical services and drugs to help manage their chronic conditions.

2) Extend the flexibilities available under the Medicare Advantage (MA) V-BID Demonstration permanently to MA plans. Enact legislation encouraging the Centers for Medicare and Medicaid Services (CMS) to issue regulations extending recent flexibilities made available under the MA V-BID Demonstration (e.g., telehealth network requirements, rewards and incentives flexibilities, etc.) more broadly to MA plans, including MA Part D plans (MA-PD), so that MA and MA-PD plans may offer clinically nuanced plan designs that benefit patients with chronic conditions.

3) Address Wasteful Spending by Disincentivizing Low-Value Care. Pursue efforts to reduce spending on unnecessary, duplicative, and/or potentially harmful health care services by incentivizing high-value care and disincentivizing low-value care.

INCREASE ACCESS TO HIGH-VALUE CARE FOR CHRONICALLY ILL PATIENTS WITH HSA-QUALIFIED HDHPS
The Coalition strongly urges the Administration to promulgate regulations or Congress to pass legislation to allow high deductible health plans (HDHPs) coupled with Health Savings Accounts (HSAs) to offer chronic care services and drugs to patients on a pre-deductible basis by expanding the current preventive care safe harbor (section 223(c)(2)(C) of the Internal Revenue Code).1 Doing so could remove cost barriers for millions of chronically ill Americans to access critical health care services to help manage their illnesses.

Congress created HSAs in 2003 with the provision that these accounts would only be available to those enrolled in qualifying HDHPs. The tax advantages of HSAs and lower HDHP premiums have driven rapid uptake among employers. Studies show the percentage of employers offering HDHPs grew by 20 percent between 2005 and 2017, and the percentage of employees covered by HDHPs over the same period grew by 24 percent.2 Additionally, the Kaiser Family Foundation’s 2017 Employer Health Benefits Survey shows average annual deductibles increased 89 percent between 2010 and 2017.

Guided by the Internal Revenue Service (IRS) safe harbor under section 223(c)(2)(C) of the Internal Revenue Code, HSA-eligible HDHPs may provide coverage of some preventive services prior to satisfaction of the deductible, including, for example, mandatory coverage of US Preventive Services Task Force (USPSTF) recommended services and vaccines recommended by the Advisory Committee on Immunization Practices (ACIP).

HSA-HDHPs are currently prohibited from offering services and medications to manage an individual’s chronic conditions on a pre-deductible basis, creating financial and access barriers to care for chronically ill patients such as those with diabetes, asthma, mental health disorders, and opioid addiction. While primary prevention (e.g., USPSTF services and immunizations) is important, the Centers for Disease Control and Prevention estimates 90 percent of the nation’s $3.3 trillion in annual health expenditures are for people with chronic and mental health conditions. Without appropriate management, these conditions can often lead to adverse effects on quality of life and can cause preventable, premature death.

Employers and health plans offering HSA-HDHPs should be permitted the option and flexibility to make chronic disease preventive services and drugs available on a pre-deductible basis to chronically ill individuals. This will help increase access to necessary services, encourage adherence to treatment and/or medication care plans, and, in certain clinical circumstances, reduce total health care spending. The Coalition urges policymakers to modernize what qualifies as ‘preventive care’ under the statutory safe harbor to enhance access to these potentially life altering services and drugs.

Recommendation: The Coalition commissioned a legal analysis stating the Administration has the legal authority to define preventive care to include chronic disease prevention, and we urge you to encourage the Administration to utilize this authority and make it possible for employers and health plans to decrease out-of-pocket spending for millions of Americans with HSA HDHPs. If the Administration does not act, we strongly urge you to include the provisions of the Chronic Disease Management Act of 2018 (H.R. 4978 / S. 2410) in any package that is considered by the Committee to address rising health care costs. This bipartisan, bicameral legislation allows HSA-HDHPs to cover health care services and medications that manage chronic conditions on a pre-deductible basis with greater employer and plan flexibility, consistent with the principles of V-BID. Doing so will benefit patients, employers, and payers alike, including improved health, enhanced workplace productivity, and the avoidance of unnecessary emergency care visits and hospitalizations and will ensure a more rational and sustainable health care system.

EXTEND THE FLEXIBILITIES AVAILABLE UNDER THE MA V-BID DEMONSTRATION PERMANENTLY TO MEDICARE ADVANTAGE PLANS
Last year, CMS increased the flexibility in MA uniformity requirements and supplemental benefits by allowing MA plans the ability to reduce cost-sharing amounts for certain covered benefits, offer specific tailored supplemental benefits, and offer lower deductibles for MA enrollees that may meet specific medical criteria. Under this flexibility, MA plans have the ability to tailor the cost-sharing and benefits to their enrollees based on “objective and measurable” medical criteria. CMS further expanded these flexibilities this year, allowing MA plans to offer non-primarily health related benefits based on individual needs of their members. The Coalition strongly supports and commends the agency for these flexibilities that would allow MA plans to apply V-BID principles to the cost-sharing and other benefits offered to their enrollees. However, there are still limitations within MA that could be informed by the MA V-BID Demonstration. For example, the uniformity requirements afford flexibility only to Part C and not Part D. The Coalition strongly supports extending the uniformity flexibility to Part D. Additionally, the Center for Medicare and Medicaid Innovation (CMMI) introduced new flexibilities for telehealth network requirements, rewards and incentives maximums, tailoring care based on socioeconomic status, etc. under the MA V-BID Demonstration that are not available in traditional MA plans.

Recommendation: The Coalition encourages you to enact legislation encouraging CMS to issue regulations extending recent flexibilities made available under the MA V-BID Demonstration (e.g., telehealth network requirements, rewards and incentives flexibilities, etc.) more broadly to MA plans, including MA-PDs. Broader adoption of V-BID Demonstration flexibilities in MA will help ensure that patients continue to have more accessible and affordable options for prescription drugs. Such legislation should ensure the current uniformity flexibility afforded to Medicare Part C also extends to Part D.

ADDRESS WASTEFUL SPENDING BY AVOIDING LOW-VALUE CARE
Studies estimate the U.S. spends hundreds of billions of dollars on low-value medical care, defined as services and drugs that provide little to no clinical benefit.3 Low-value care also exposes patients to harm, imposes high and unnecessary out-of-pocket costs, and can lead to lost productivity. In addition, low-value care crowds out the ability of our health care system to pay for the things that actually improve our health or maintain our well-being, such as chronic disease management or precision medicine.

For example, several physician organizations have concluded that there is a preponderance of evidence that many pre-operative tests are wasteful.4 Most patients undergoing low-risk surgery do not need laboratory tests such as complete blood counts, basic or comprehensive metabolic panels, or coagulation studies. Prior to non-cardiac surgery, low-risk patients also do not need baseline diagnostic cardiac testing, such as stress tests. Other professional societies advise against needless pulmonary function testing and routine chest x-rays – a source of unnecessary radiation – before surgery. Incidental findings from unnecessary pre-surgical testing can lead to downstream risks, avoidable costs, and unnecessary delay of evidence-based care. Often, these tests provide no information that will change the course of treatment or surgery. Extrapolating data from a study in Virginia, an estimated 19.2 million unneeded pre-surgery tests and imaging services were performed in 2014 across the country. These services accounted for about $9.5 billion in avoidable spending.5

In addition to unnecessary pre-operative testing, the U.S. federal government continues to pay for unnecessary screenings that cost the taxpayers millions of dollars in upfront costs. For example, in 2014 the Medicare program paid upwards of $79 million for prostate-specific antigen (PSA) screenings for men over 75.6 The USPSTF, designed to assess available evidence regarding the value of primary preventive services, ranks PSA screenings for men over 70 as a D-rated service.7 A “D-rated” services means that there is significant clinical evidence to suggest that the harms of the service significantly outweigh the benefits.8 The Medicare Payment Advisory Committee (MedPAC) released a list of 31 low-value care services covered by Medicare, which accounted for up to $6.5 billion in estimated wasteful spending – between 34 and 72 percent of Medicare fee-for-service beneficiaries received at least one low-value service in 2014. Included in that list are PSA screenings and pre-operative testing, among others.

The dollar estimates represented above do not take into consideration the downstream, cascading effects of incidental findings as a result of unnecessary testing or the subsequent medical costs due to iatrogenic harm associated with low-value care. PSA screenings for example often lead to unnecessary, invasive biopsies or prostatectomies that come with their own host of risks and costs. The dollar estimates also do not include out-of-pocket costs, which can be very high and the result of care that was not needed in the first place.

Recommendation: The Secretary of Health and Human Services is already empowered to act to address low-value preventive services. The Affordable Care Act (ACA) included a provision that would allow the Secretary to not pay for USPSTF D-rated preventive services (Sec. 4105(a)).9 However, HHS has yet to act on this section of the ACA. Doing so would encourage evidence-based medicine, reducing harm to Medicare patients, and freeing federal dollars for medical care that is clinically proven and effective. Congress should urge the Secretary to utilize this existing authority. Additionally, Congress could commission a GAO study on low-value preventive care and the extent to which the Secretary could use existing authorities to stop paying for care that unequivocally does more harm than good, including a thorough study of the cost savings potential of expanding the scope of the Secretary’s authority to address low-value care.

*****
Mr. Chairman and Ranking Member Murray, thank you for your attention to the important matter of addressing rising health care costs in the United States. We encourage you to advance the recommendations above to ensure that we constrain health care costs while ensuring the best care for patients.

Sincerely,

Andrew MacPherson, Co-Director Ray Quintero, Co-Director Katy Spangler, Co-Director

PCPCC's Top 10 Accomplishments in 2018

January 8, 2019

With the help of our broad multisector membership of thought leaders and influencers in the health care space, PCPCC had numerous accomplishments that we’ve captured in a top 10 list. Our collective power is clearly impressive. Together we’ve demonstrated that we can make a significant impact to advance primary care. 

PCPCC Sends Senate Letter Urging Passage of the Comprehensive Care for Seniors Act

November 5, 2018

November 5, 2018

Dear Senator: 

The Patient-Centered Primary Care Collaborative (PCPCC) encourages the passage of the Comprehensive Care for Seniors Act of 2018 (S.3338) before the end of the 115th Congress.  PCPCC believes that Programs of All-Inclusive Care for the Elderly (PACE) exemplify many of the goals found in our Shared Principles of Primary Care – namely an emphasis on high-value care primary care that is coordinated, integrated, team-based, and incorporates patient and family caregivers.

The legislation would require CMS to finalize updated regulations for Programs of All-Inclusive Care for the Elderly (PACE), that were originally proposed in 2016. PACE programs are fully risk bearing and utilize capitated payments to offer a full range of services and supports to Medicare and/or Medicaid beneficiaries who are at least 55 years old and qualify to be in a nursing home, according to their state.  The forthcoming final rule is expected to strengthen protections and improve care to beneficiaries, while providing administrative flexibility and regulatory relief for PACE organizations.

Founded in 2006, the PCPCC is a not-for-profit multi-stakeholder membership organization dedicated to advancing an effective and efficient health system built on a strong foundation of primary care and the patient-centered medical home. Representing a broad group of public and private organizations– the PCPCC’s mission is to unify and engage diverse stakeholders in promoting policies and sharing best practices that support growth of high-performing primary care to achieve the “Quadruple Aim”: better care, better health, lower costs, and greater joy for clinicians and staff in delivery of care.

PCPCC’s Shared Principles of Primary Care, now endorsed by nearly 300 organizations, support care primary care that is grounded in mutually beneficial partnerships among clinicians, staff, individuals and family caregivers as equal members of the care team. Care delivery is customized based on individual and family strengths. Because of its patient centered focus, this legislation aligns with PCPCC’s goal of promoting integrated, coordinated, and patient-centered healthcare ultimately leads to better outcomes and value.

The PACE program, with enrollments across 31 states, is a person-centered model of care delivery. The interdisciplinary team approach enables participants to remain in the community. Given that PACE payments are capitated, paid monthly by CMS to the PACE provider using formulas that incorporate risk adjustment, this payment model promotes comprehensive, high value care and disincentivizes fragmented care provision to these medically-complex individuals, as often is the result in Medicare fee-for-service.

Thank you for your consideration of this important legislation. PCPCC and its multisector members look forward to working with you to enact polices which promote high value care as well as person-centered, team-based, community aligned primary care. Those ends will help achieve the goals of better health, better care, and lower costs and advance innovation in our   healthcare system as a whole.  Please feel free to contact Christopher Adamec, Director of Policy at cadamec@pcpcc.org or 202-640-1212 with any questions.

Sincerely,
 

Ann Greiner

President & CEO


(sent to multiple Senators)

PCPCC Encourages Senate to Expand Access to High-Value Preventative Care

November 2, 2018

November 5, 2018

The Honorable Orrin G. Hatch                      The Honorable Ron Wyden
Chairman, Senate Finance Committee          Ranking Member, Senate Finance Committee
U.S. Senate                                                    U.S. Senate
219 Dirksen Senate Office Building               219 Dirksen Senate Office Building
Washington, DC 20510                                  Washington, DC 20510

Dear Chairman Hatch and Ranking Member Wyden:

The Patient-Centered Primary Care Collaborative (PCPCC) encourages the Senate to act to preserve and expand access to high-value preventative care for consumers with high-deductible healthcare plans (HDHP) coupled with health savings accounts (HSAs). PCPCC is concerned that, despite increasing access to health insurance, more consumers are skipping high-value preventative primary care – most likely due to out of pocket costs associated with high deductibles.

While there are many important steps that could be taken to address this challenge, two are currently before the 115th Congress and enjoy widespread support for inclusion this year:

  • The Chronic Disease Management Act of 2018 (H.R. 4978 / S. 2410) would allow HSA-eligible HDHPs to provide plan members access to specific high-value health care services and medications that manage chronic conditions on a pre-deductible basis.
  • First Dollar Coverage Flexibility for High Deductible Health Plans - Key provisions in Section 2 of the Restoring Access to Medication and Modernizing Health Savings Accounts Act of 2018 (H.R. 6199) would allow health plans to provide pre-deductible coverage of up to $250 a year for an individual and $500 a year for family.

These changes could provide meaningful flexibility for health plans to provide coverage for and incentivize the use of high-value services that can reduce health care costs more broadly, such as primary care visits and telehealth services.  Higher coverage limits should also be strongly considered, as both retain the ability of the health plan to identify and cover services that are proven to be meaningful, high-value interventions.  

Founded in 2006, the PCPCC is a not-for-profit multi-stakeholder membership organization dedicated to advancing an effective and efficient health system built on a strong foundation of primary care and the patient-centered medical home. Representing a broad group of public and private organizations– the PCPCC’s mission is to unify and engage diverse stakeholders in promoting policies and sharing best practices that support growth of high-performing primary care to achieve the “Quadruple Aim”: better care, better health, lower costs, and greater joy for clinicians and staff in delivery of care.

Thank you for your consideration of this important legislation. PCPCC and its multisector members look forward to working with you to enact polices which further population health and more specifically advance primary care as foundational to high-value care.  Please feel free to contact Christopher Adamec, Director of Policy at cadamec@pcpcc.org with any questions.

Sincerely,

Ann Greiner

President & CEO

PCPCC Comment Letter: Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems

September 24, 2018

PCPCC submitted comments to the Centers for Medicare and Medicaid Services supporting changes in the Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems that seek to align payment rates across settings, so that patients can choose the setting that best meets their needs. PCPCC wrote that the transition to alternative payments that reward value requires a site-neutral payment system that does not incentivize a specific setting.

PCPCC Highlights Key Priorities in Comments to CMS on the Physician Fee Schedule and Quality Payment Program

September 10, 2018

Re: Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program [CMS–1693–P]

The Patient-Centered Primary Care Collaborative (PCPCC) appreciates this opportunity to provide several comments on the proposed physician fee schedule and quality payment program. We applaud the administration for proposing bold changes designed to move the health system forward while also seeking to improve care delivery and reduce clinician administrative burden. PCPCC continues to support Centers for Medicare & Medicaid Services (CMS) efforts to expand the use of value-based and alternative payment models, while simultaneously reducing documentation requirements that are less necessary under payment models tied to outcome measures.

PCPCC Comments on the Importance of Title X for Primary Care

July 30, 2018

The Honorable Alex Azar
Secretary
U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue SW
Washington, DC 20201

Attention: Compliance With Statutory Program Integrity Requirements (Family Planning)

Dear Secretary Azar:

The Patient-Centered Primary Care Collaborative (PCPCC) appreciates this opportunity to provide comment on the administration proposal to revise regulations pertaining to Title X of the Public Health Service Act. PCPCC would like to express concern over potential health outcomes of the proposed rule, particularly on lower-income and medically underserved patients.  PCPCC believes that the exclusion of health clinics providing a full range of family planning services from Title X would undermine our nation’s public health and weaken an important component of America's primary care delivery system.

Title X is the only federal program exclusively dedicated to providing low-income and adolescent patients with essential family planning and preventive health services and information. Evidence-based sexuality education programs help young women achieve their educational and professional goals by educating them about sexual health, including preventing unintended pregnancy and family planning. These and other federal programs must continue to provide non-directive, comprehensive, medically accurate information.

As noted by a recent article in Health Affairs, "the rule is likely to have a major, harmful, and lasting impact on access to family planning, which is recognized by the Centers for Disease Control and Prevention (CDC) as one of the 10 most important public health advances of the twentieth century."(1) It also cites analyses indicating that the change could lead to a resulting surge in demand on community health centers and public health agencies – a strain that would undermine other important primary care and public health goals.

PCPCC strongly believes that clinicians providing critical primary care services should be guided by evidence-based best practices that are tailored to the needs of the patient.  Trust is an essential component of this patient-provider relationship. This trust would be drastically undermined by real or perceived restrictions on what the clinician can discuss or recommend for the patient. PCPCC strongly encourages the Department of Health and Human Services (HHS) to review the principles issued by the American Academy of Family Physicians (AAFP), American Academy of Pediatrics (AAP), American College of Obstetricians and Gynecologists (ACOG) and American College of Physicians (ACP) on "Protecting the Patient-Physician Relationship: Keeping External Interference Out of the Practice of Medicine."  These principles call on policymakers to:

"Reject government restrictions on the information our patients can receive from their doctors.  Patients expect medically accurate, comprehensive information from their physicians; this dialogue is critical to ensuring the integrity of the patient-physician relationship. No governmental body should interfere in our members’ obligation to provide evidence-based information to their patients. When our government restricts the information that can be given to women, or forces physicians to provide women with non-medically inaccurate information, we can expect increased rates of unplanned pregnancy, pregnancy complications, and undiagnosed medical conditions."(2)

Founded in 2006, the Patient-Centered Primary Care Collaborative is a not-for-profit multi-stakeholder membership organization dedicated to advancing an effective and efficient health system built on a strong foundation of primary care and the patient-centered medical home.  Representing a broad group of public and private organizations – including payers, healthcare clinicians and other providers, leading corporations and patient and consumer advocacy groups – the PCPCC’s mission is to unify and engage diverse stakeholders in promoting policies and sharing best practices that support growth of high-performing primary care to achieve the “Quadruple Aim”: better care, better health, lower costs, and greater joy for clinicians and staff in delivery of care.

Thank you for requesting input on the proposal to revise regulations pertaining to Title X of the Public Health Service Act.  PCPCC and it members look forward to a final rule that recognizes and supports the critical role of family planning services under Title X in providing access to comprehensive primary care to all Americans.

Sincerely,

Ann Greiner

President & CEO

 

[1] “The Title X Family Planning Proposed Rule: What’s At Stake For Community Health Centers?, " Health Affairs Blog, June 25, 2018.DOI: 10.1377/hblog20180621.675764

[2] “Joint Principles for Protecting the Patient-Physician Relationship”  https://www.acponline.org/acp-newsroom/joint-principles-for-protecting-the-patient-physician-relationship

PCPCC STATEMENT ON RISK ADJUSTMENT FUNDING

July 26, 2018

 

PCPCC STATEMENT ON RISK ADJUSTMENT FUNDING

The Patient-Centered Primary Care Collaborative (PCPCC) appreciates the announcement by the Centers for Medicare and Medicaid Services (CMS) that it will reissue, with additional explanation, the risk adjustment methodology that CMS previously established for transfers related to the 2017 benefit year. The availability and consistency of risk adjustment program funding is imperative to protecting patients by allowing insurers to compete without cherry-picking healthy consumers.

PCPCC and its multistakeholder membership were extremely concerned by the previous suspension of the program and urge continuity in risk adjustment payments. Withholding these funds would have had major implications on healthcare affordability and healthcare access for patients. Lack of clear federal commitment to these payments may have already affected insurance markets, and any additional delay may cause insurers to substantially increase premiums in 2019 to make up for the loss in revenue, adversely affecting patients. 

The risk adjustment program protects insurers from unanticipated costs by providing payment support to enroll higher-risk people, such as those with chronic or pre-existing conditions -- without relying on supplemental taxpayer dollars. It helps create a more diverse insurance pool by removing the incentive to only enroll healthier individuals.

Stabilization of the program is key.  Payment undermines access for patients through increased costs – further straining patient ability to maintain an ongoing relationship with their primary care provider.  Evidence shows that primary care is highly underutilized in our healthcare system, and that greater access to primary care leads to better overall population health and lower total costs. We are pleased that the administration and CMS recognized the urgency of this matter and prioritized stabilization of the market.

Founded in 2006, the PCPCC is a not-for-profit multi-stakeholder membership organization dedicated to advancing an effective and efficient health system built on a strong foundation of primary care and the patient-centered medical home. Representing a broad group of public and private organizations – including payers, healthcare clinicians and other providers, leading corporations and patient and consumer advocacy groups – the PCPCC’s mission is to unify and engage diverse stakeholders in promoting policies and sharing best practices that support growth of high-performing primary care to achieve the “Quadruple Aim”: better care, better health, lower costs, and greater joy for clinicians and staff in delivery of care.

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