President Trump’s administration has made it clear that they plan to greatly alter, if not repeal, the Affordable Care Act. To both sides of the political isle it may come as a surprise that altering the Affordable Care Act will likely have little impact on a core outcome of health reform: the fact that private insurance companies increasingly pay primary care providers for improved health outcomes. Since the presidential election, we have met with a dozen payers in both red and blue states: Arkansas, Florida, Louisiana, Mississippi, Missouri, New Jersey, Pennsylvania, Utah, and West Virginia. Not one payer has mentioned that they plan to stop their efforts, or pull back resources dedicated to moving physicians away from the fee-for-service paradigm and towards paying for outcomes. In fact, every payer we meet is intent to continue to innovate by paying providers in a manner that lowers cost and improves health.

A key piece of the Affordable Care Act created the Medicare Shared Savings Program, and private payers quickly followed with their own efforts to move physicians to shared savings contracts. Years later, private payers continue to dedicate significant resources to move providers away from fee for service and towards value payments. And payers have committed to move all of their providers, across all business lines (commercial, Medicare Advantage, and Managed Medicaid), to value. This investment has been significant. For example, Cigna established CareAllies, a service company that works with provider organizations of all types to focus on improved patient outcomes and better health care quality and affordability. Similarly, UnitedHealthcare (via Optum) has gone further and purchased providers in order to create high value networks and their own Accountable Care Organizations. Humana has a well-established value path (the Accountable Care Continuum) that moves its Medicare Advantage providers away from fee for service on a path towards global capitation. Each of these national payers have undertaken vast strategic efforts that require significant resources for staff and infrastructure, and a change in culture.

Commercial payers believe, and have the data to demonstrate, that paying for value lowers their cost and improves the health of their members. For example, UnitedHealthcare has noted up to 6 percent lower medical costs across a range of value-based care programs, and overall, commercial ACOs have lower expenses per Medicare enrollee and slightly higher quality-of-care scores.

Despite the threat of repealing parts or all of the Affordable Care Act, our payer partners continue to move ahead with their payment reform efforts. The political battle over Obamacare has had no impact on payers’ dedication to reform provider payments; the future of primary care provider payment remains value-based. Though there is still much unknown about the potential repeal and replacement of the Affordable Care Act, the future of physician payment reform is clear.

December 20, 2016

Andy Slavitt, Acting Administrator
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Re: CMS-5517-FC: Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models (81 Fed.Reg. 77008 (Nov. 4, 2016))

Dear Administrator Slavitt,

Aledade partners with over 200 primary care physician practices, FQHCs and RHCs in value-based health care. The physicians are across 15 states and are accountable for over 170,000 Medicare beneficiaries. More than half of our primary care providers are in practices with fewer than ten clinicians. As an organization that is dedicated solely to helping independent physicians lead the transition from volume to value, we have a particular set of experiences and perspectives that are highly relevant to the key policy issues faced by CMS in implementing the MACRA legislation.

As described in more detail in our comment letter, a few critical improvements to the final MACRA regulation could improve the uptake of accountable care.
1. Creating a new MSSP model that takes advantage of the breakthroughs in the MACRA regulations regarding risk and matches that risk with proper rewards
2. Allowing independent practices to come together in “virtual groups” now for all aspects of MIPS reporting, and rewarding their clinical practice and health IT advances as they work towards participation in APMs (like gain share only ACOs) and on to AAPMs
3. Simplifying provisions related to other payer APMs and Certified EHR Technology
Thank you very much for your consideration as we move together through this exciting time in health care. Please feel free to follow up with me or Travis Broome (travis@aledade.com) if you or your staff have questions or would like to explore these positions further.

Sincerely,
/s/
Farzad Mostashari, MD
CEO and Co-Founder, Aledade, Inc.

Advanced APM Revenue-Based Nominal Amount Standard

CMS seeks comment for future consideration on the amount and structure of the revenue-based nominal amount standard for QP Performance Periods in 2019 and later. This includes: (1) setting the revenue-based standard for 2019 and later at up to 15 percent of revenue; or (2) setting the revenue-based standard at 10 percent so long as risk is at least equal to 1.5 percent of expected expenditures for which an APM Entity is responsible under an APM.

In our comments on the MACRA proposed rule we supported a 15 percent of revenue standard out of the gate to simplify the requirements. We continue to believe that 15 percent represents more risk than any other path under MACRA and more than satisfies the Congressional standard of more than nominal risk. In response to CMS’s request for comment, we want to highlight the critical nature of maintaining both a revenue based standard and a percentage of model benchmark standard. Using a percentage of model benchmark standard creates vastly different amounts of risk depending on the organization and depending on the APM model. How risky something is to an organization is dependent on the level of risk relative to their financial situation. This variation creates a situation where CMS will not be able to gauge the amount of financial risk any APM entity is actually taking on. What could be disastrously risky for one organization could be less than nominal for another organization.

Reintroducing a model benchmark standard to the revenue standard reintroduces all that was wrong with the standard in the first place, namely that the financial risk would in no way be related to the financial standing of the organization. If Congress had not asked CMS to measure financial risk this would not be a concern; however, Congress clearly wanted the APM entity to take on more than nominal financial risk. This means financial risk should be measured and it should be measured in relation to the APM entity not the AAPM. For these reasons CMS should maintain a pure revenue-based standard that stays well ahead of the risk in MIPS and finalize in the future a 15 percent of revenue standard.

CMS furthers asks for comment on cases where the APM Entity is one component of a larger health care provider organization and using the larger organization as the basis for a revenue-based nominal amount standard. To minimize the revenue based standard, a health care organization could limit the composition of its APM entity to only those health care providers who drive attribution in the model. We do not believe it is necessary for CMS to consider this in determining the revenue-based nominal amount for several reasons. First, by limiting the participants in the AAPM the health care provider organization would lose all the benefits of having those health care providers in the AAPM and that in and of itself has cost. Second, not all models use the same attribution methodologies and certainly do not have the same economics so what might seem wise in one model to include the larger health care organization may not make sense in another model and could inadvertently drive large health care organizations out of some models. Finally, by including the alternative pure percentage of benchmark standard for nominal financial risk CMS already has an alternative for larger health care organizations for whom the benchmark standard may only represent 15% of revenue or less for larger health care organizations. By having both a pure revenue standard and a pure percentage of benchmark standard, CMS ensures that all APM entities are taking on more than nominal financial risk while still allowing flexibility to account for the incredible diversity that is some larger health care organizations.

ACO Track 1+ Model
The most obvious work left undone by MACRA is having an ACO that matches the risk standards finalized in MACRA. We believe it is imperative that CMS implement an ACO model that does so as quickly as possible. We field questions everyday as to whether our ACOs will move to two-sided risk. Every day that goes by where we have to say we do not know is a lost opportunity. We continue to believe that the most straightforward way to implement just the new risk standards would be through the MSSP itself.

This risk can be easily integrated as a stop loss scenario into Track 2 and Track 3 with the addition of one line of regulation text each for Track 2 and Track 3 MSSP ACOs. Changes are in bold with higher risk for Track 3 due to its higher reward.

For Track 2: 42 CFR 425.606 (g)
(3) 3 percent in the third and any subsequent performance year, or
(4) 8 percent of the Medicare Parts A and Part B revenue of the ACO participants in any performance year 2017 and 2018.

For Track 3: 42 CFR 425.610
(g) Loss recoupment limit. The amount of shared losses for which an eligible ACO is liable may not exceed 15 percent of its updated benchmark as determined under § 425.602 or 15 percent of the Medicare Parts A and Part B revenue of the ACO participants in any performance year.

However, we understand that CMS is on the path to implement it as an innovation model. This means there is at a minimum additional one additional piece of work to be accomplished. CMS must outline the reward that ACOs receive for taking on risk. While CMS may be tempted to see the 5% fee-schedule bonus as sufficient, we assure you it is not. First, many ACOs include participants who do not receive Part B payments in a significant way such as FQHCs, RHCs and hospitals. Secondly, most physicians (rightly or wrongly) believe they can achieve 5% in MIPS. Combining these two factors essentially negates the value of the 5% bonus for taking on risk. Finally, even in the rare scenario where all ACO participants only receive Part B payments the risk is still mathematically higher than the reward. The combination of these factors means it is imperative that the model itself offer reward for taking on risk. We recommend that CMS include in the model the potential for 60 percent shared savings for 8% of revenue risk and 75 percent shared savings for 15% of revenue risk.

As CMS is developing a new model we believe CMS can take this opportunity to focus on more than the risk reward tradeoff. The model can test other ways to bring the ACO model closer to measuring whether a person in the ACO get better care at lower cost than if the person had not in the ACO or a “difference in difference” approach.

We recommend CMS address two additional areas that are crucial towards moving physicians towards taking risk. First, CMS should change how it views risk adjustment. Rather than the current view of fear that it will lead to paying for coding, CMS should focus on the true purpose of risk adjustment which is make different populations comparable to one another. We have advocated, along with many others, for the last two years that to measure real ACO value risk scoring must accurately reflect the measured population. The artificial cap imposed by CMS on risk scoring turns ACOs into mini-insurance companies. This in turn scares ACOs away from two-sided risk because they are no longer responsible for just population health, but also statistical anomalies. This is the only area where CMS is not leading the accountable care movement, but falling behind commercial health plans.

The second important step CMS can take to measuring ACO value is to include regional inflation update factors instead of national inflation update factors in all contract years. CMS should seek to reward ACOs for the work they do in creating difference in difference ACO value not because they happen to be in a low cost or high cost area in any given year. CMS’s own analysis for their last regulations on the MSSP shows that very few ACOs can individually impact their area’s cost curve. Every ACO can impact whether the person got better care in the ACO than they did out of it. A regional inflation update ensures that the work of the ACO impacts the ACO’s financial future instead of regional cost arbitrage. ACOs have begun to calculate headwinds and tailwinds (i.e. is the benchmark lower or higher than the most recent year’s costs) to determine their likelihood of success. This is what CMS intended to reward areas with falling costs with more ACO participation. However, this intent has gone awry. First, rarely does any individual ACO have significant impact on their regional costs so the reward or penalty is not due to the past work of the ACO participants. Second, ACOs have not been able to determine these headwinds or tailwinds prior to receiving ACO data from CMS so the phenomenon cannot drive increases or decreases in ACO participation. Given that the hoped for effects of this policy have not materialized it is time to revert to the more accurate measurement of regional inflation in benchmarking and annual update factors in the first contract and end the unnatural arbitrage opportunities national inflation updates are causing across the MSSP.

Other Payer Advanced APM Financial Risk Criteria
We strongly believe that CMS should use the exact same criteria for qualifying other payer APMs as advanced as those used for Medicare. Both payers and health care providers should be able to submit the parameters of their program for qualification as an AAPM. CMS should be as open as possible in disclosing the specific qualifying terms of the other payer APMs, but should offer enough proprietary protection so that a health care provider is able to submit the parameters on their own.

Definition of Certified EHR Technology
We believe that CMS should not attempt to create different versions of meaningful use (now referred to as Advancing Care Information) through the AAPM requirements. CMS should, as they finalized in this regulation, define use simply as use of Certified EHR Technology in the AAPM. Different AAPMs will have different health information technology needs. They will all have a need to keep medical records and to make those records available to patients, care givers and other health care providers which is why we support the requirement that the EHR Technology be certified, but specific uses, measurement of those uses and the effects on the financials of the AAPM should be allowed to vary significantly from AAPM to AAPM.

Virtual Groups
Not all MIPS eligible clinicians are ready to participate in an APM. By laying out the framework for the virtual groups, CMS can make it a viable alternative for physicians in 2018. By serving as an alternative to consolidation, virtual groups can stem the revenue shift from small to large practices projected in the impact statement which in turn stems consolidation and preserves competition. We put forward a potential outline of virtual group as part of our comments.

How a virtual group is formed:

  • Voluntary election by physicians to be in a virtual group prior to the start of the performance year
  • Agree to work together to improve quality and other elected components of MIPS
  • Must agree to be scored on quality component
  • Can elect to be scored on
  • Clinical Practice Improvement Activities
  • Advancing Care Information
  • Resource Use
  • Can utilize any reporting method including Group Practice Reporting Option (GPRO)
  • Identify to CMS the officer responsible for the virtual group’s reporting

CMS already has several online systems for physician interaction regarding quality such as Quality Net, EIDM and HPMS. Any one of this could be adapted to record the grouping of the Taxpayer Identification Numbers that represent practices and to collect the election of which components of MIPS to be scored on.

Governance of the Virtual Group:

  • Establish a board with beneficiary representation to govern the virtual group
  • Empower an officer to take responsibility for the virtual group’s reporting
  • Establish a compliance officer
  • Conduct at least quarterly group reviews of their work toward improved quality

Responsibility of the Virtual Group:

  • The physicians and other eligible professionals agree to be scored as a group for purposes of MIPS
  • The virtual group is responsible for ensuring group reporting (i.e. CMS should not be responsible for aggregating the data across practices except in the area of resource use and other claims based measures)
  • The virtual group should have the capability to generate practice level information within the group (CMS will provide scoring at the virtual group level)

Limitations of the Virtual Group:

  • The sole purpose of the virtual group is to comply with MIPS reporting and it does not infer other advantages to the practices in regards to waivers or other exceptions
  • Virtual groups seeking additional group activities should seek to become an existing, more advanced group such as a clinically integrated network and/or an accountable care organization
  • Practices commit to a minimum of one year to being scored under MIPS as part of the virtual group

Last Friday, the Centers for Medicare & Medicaid Services (CMS) released the highly anticipated final regulations implementing the Medicare Access and CHIP Reauthorization Act (MACRA). MACRA creates two value driven ways of interacting with CMS: Advanced Alternative Payment Models (AAPMs) and the Merit-Based Incentive Payment System (MIPS). Here is what you need to know about each. CMS listened to and responded to a vast array of comments from health care stakeholders. I believe the rule will move the country to where doctors are reimbursed for quality and value not volume. In creating a clear path for small, independent physicians to embrace the transition to value, CMS makes it possible for leading independent practices to reduce costs, boost outcomes, and thrive.

Advanced Alternative Payment Models: What You Need to Know

Most commonly taking the form of accountable care organizations and bundled payment initiatives, the defining characteristic that make an alternate payment model “advanced” is risk. Risk is usually simply defined as poor performance means I will have to write CMS a check. The critical question was how big does the check have to be to qualify. CMS originally proposed that the check had to be a percentage of the denominator in the model so in an ACO a percentage of total cost of care or in bundles a percentage of the total bundle price. Yet as we detailed in blog posts (here, here and here) as well as in our formal comments to the proposed rule this would have disadvantages smaller, physician-led groups that represent only a small percentage of the total cost of care.

Therefore, we are very pleased to see CMS simplify how they measure the amount of risk and relate it to the financial resources of those participating in the APM entity. CMS recognizes that not all APM entities have the same financial resources so it is impossible to use the same standard for all and claim that the risk is merely more than nominal for all of them.

CMS finalized for 2017 and 2018 that risk representing 8 percent of the Medicare Part A and Part B revenue received by participants of the ACO or other APM would qualify the APM as advanced. CMS also indicated that this could ramp up over time to as much as 15 percent in later years. This would ensure that participation in an AAPM always entails more risk than participation in MIPS, a goal we support.

Advanced Alternative Payment Models: What to Watch For

This is just the first step. Today no two-sided risk APM takes advantage of this motivational level of risk. CMS indicates in it regulation that updates to existing APMs are coming very quickly. In particular CMS talks about a MSSP Track 1+ that would take advantage of this lower risk track in time for physicians to be in it for 2018 which would affect their payments in 2020. We look forward to seeing CMS move quickly to catch their various models up to this final rule.

While not an issue for most ACO participants, physicians should be aware that they must have at least 25% of their Medicare Part B services or at least 20% of their Medicare Part B patients attributed to the APM to individually qualify for the 5% bonus payment. Nearly every primary care physician in an ACO model will easily push past these thresholds, but specialists and physicians in other models should be wary of this provision especially as it ramps up to 50% and 35% respectively in 2021 (reporting year 2019) and all the way to 75 and 50% in 2023 (reporting year 2021).

Medicare Incentive Payment System: Need to Know

CMS recognized that with 2017 starting in just two and a half months and calls 2017 what it was always going to be: a transition year. To successfully navigate the transition year there are two number to know: 3 and 70. 3 is how many points you need in 2017 to avoid any penalty in 2019. 70 is how many points you need to gain access to the $500 million exceptional performance bonus pool that Congress created.

MIPS is divided into four categories that total up to 100 possible points.

2017 Breakdown of Points by Category

Category

MIPS only Points

MIPS with ACO Points

Quality

60

50

Improvement Activities

15

20

Advancing Care Information

25

30

Cost

0

0

 

2018 Breakdown of Points by Category

Category

MIPS only Points

MIPS with ACO Points

Quality

50

50

Improvement Activities

15

20

Advancing Care Information

25

30

Cost

10

0

 

To get the 3 points you need only successfully report one measure for one category. This prevents any 2019 negative payment adjustments. A low bar to be sure, but you must interact with CMS in 2017 at least this much or you will receive a negative 4% adjustment in 2019.

Because CMS expects most physicians to at least report one measure, there will not be a lot of positive payment adjustments available under budget neutrality rule. This means most of the positive potential in MIPS is tied to the exceptional performance bonus pool. To access this pool, you must report at least 90 days preferably the whole year and earn at least 70 points. While it appears possible to get there while ignoring one of the categories other than quality this is not advisable. Each category has some built in low hanging fruit (for example you get 50% of the points in Advancing Care Information just for having 5 specific EHR capabilities) that should not be missed. Every organization should look into the three scored categories and plot their best way to get to at least seventy points.

To start you on that path, improvement activities is the easiest category and as mentioned you get 50% of the points in ACI just for fully implementation of your EHR. That is 22.5 points right there in MIPS only and 35 points in MIPS with ACO, certainly a solid base to start from. If you have done PQRS before, if you have done meaningful use before and certainly if you are in an ACO or other “non-advanced” APM then look into how you can be in that exceptional performance pool right away. If those things are new to you then take full advantage of 2017 as a transition year.

Medicare Incentive Payment System: What to Watch For

There are a lot of reporting submission options. Claims, registry, EHR, CMS web interface, CMS wants your data and they will take it however they can get it. If you are in an ACO your ACO quality reporting does double duty. If you aren’t in an ACO or ACO won’t be in its performance year in 2017 then you have to choose which option to use. The first consideration is what options are available to you. Is there a registry for your specialty, are you on an EHR those type of capability question. If you are capable of more than one, the second thing to keep in mind that each has its own benchmarks. So the benchmarks for CMS web interface are the same as the benchmarks used for the Medicare Shared Savings Program whether you are in an ACO or not. The benchmarks for EHR submission are based on past performance of those who submitted through EHR, etc. Benchmarks for most measures are published in advance and could influence your choice of submission method.

Bottom Line:

AAPM – Excellent news on right sized risk, but models that use it will come out in 2017

MIPS –   Must minimally interact with MIPS in 2017 to avoid penalty and if you are ready the bonus pool is within reach.

While Aledade focuses on total cost of care savings models or accountable care, there are other models moving us towards value ever day. Bundled payments (or set payment of a grouping of related services) is one of the most prominent of these other models. Medicare has several initiatives around bundle payments and just yesterday the comment period closed on the latest: a mandatory program around cardiac care. Our comments focus on the importance of quality and the interaction between ACOs and bundles. Both important areas as we all work together to achieve greater value in health care.

Andrew M. Slavitt, Acting Administrator

Centers for Medicare & Medicaid Services

7500 Security Blvd

Baltimore, MD 21244

 

Re:       CMS–5519–P:  Medicare Program: Advancing Care Coordination Through Episode Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and Changes to the Comprehensive Care for Joint Replacement Model

 

Dear Administrator Slavitt:

 

Aledade partners with 205 primary care physician practices, FQHCs and RHCs in value-based health care. Organized into sixteen accountable care organizations across 18 states these primary care physicians are accountable for over 200,000 Medicare beneficiaries. More than half of our primary care providers are in practices with fewer than ten clinicians. We are committed to outcome based approaches to determine the value of health care. We are committed to using technology, data, practice transformation expertise and most importantly the relationship between a person and their primary care physician to improve the value of health care.

To create the most value from the episode payment model (EPM) savings must come from the efforts of those participating and from quality as well as cost. There is considerable concern that bundles create opportunity for arbitrage. While this concern is somewhat alleviated by mandatory bundles, CMS must closely monitor for when savings are derived from value creation versus arbitrage. Increasing the data transparency in BCPI and mandatory bundles is an excellent first step here.

Value is not just defined as lower costs. Lower costs coupled with lower quality does not equal value creation. We support CMS’s efforts to introduce a robust quality component to EPM. We encourage CMS to include quality as a fundamental factor in the financial performance of all advanced alternative payment models.

The overlap between the episode payment models (EPM) and accountable care models (ACO) is a challenging issue in the movement to value based health care. We encourage CMS to adopt three principles as they address overlap between these models.

  1. “Do no harm” – Create absolute protection from the cost of one episode registering as savings in one model and the same episode cost registering as losses in another model
  2. Reward risk taking – Medicare beneficiaries who could be attributed to multiple models should be attributed to the model with the most risk
  3. Encourage collaboration – Remove real and perceived barriers to health care providers participating in EPMs and ACOs collaborating financially as well as clinically. Lead efforts to design attribution models that can successfully assign savings to actions of those in EPMs to those in ACOs.

Regarding the particular details of the proposed EPM itself, Aledade, Inc. is a signatory to the Health Care Transformation Taskforce’s comments and we refer you to those comments.

Principle 1: Do No Harm

The need for this principle came to light in the Bundled Care Payment Initiative or BCPI. ACOs were assigned the target price of the BCPI and this was billed as creating built in savings for the ACO; however, the ACO’s savings were capped. The reality was much different. Since the target price for BCPI was based on a blend of historic and regional costs, while the benchmark for the ACO was based on historical costs for that ACO situations arose where the target price was considerably higher, in some cases 20-30% higher, than what the episode historically cost in the ACO. This created the perverse situation where the BCPI participant would receive savings simply for not screwing up the ACOs past good work and the ACO would incur losses directly proportional to those savings. This situation created unneeded animosity between some ACOs and some BCPI participants.

It appears that the changes in CJR and the proposed EBM rule will eliminate this situation. We believe it is absolutely crucial for the transition to value based care that CMS do everything it can to prevent this situation from happening again and to monitor with extraordinary vigilance to ensure this situation does not reoccur. At the risk of hyperbole, fee for service is the enemy; however, arbitrage between the two programs creates conflicts between the programs when we should all be moving towards value.

Principle 2: Reward Risk Taking

As we will discuss in principle 3, ideally savings would be directly attributable to either the EPM participant or the ACO participant. However, that is a very difficult task prone to error. This creates a need to establish precedent for beneficiaries who are attributable to multiple models. We believe the guiding principle for the precedent should be whoever is taking the most risk should have precedent. Two-sided total cost of care risk is more than two-sided episode based risk. Two-sided episode based risk is more than one-sided total cost of care. One-sided total cost of care is more than one-sided episode based. This does not exclude collaboration between EPM participants and ACO participants. The financial incentives remain the same. Precedent simply puts the participant with the most lose in the best position to succeed.

CMS proposes to apply this principle and give precedence to the Next Generation ACO model. The exact same logic leads to the obvious conclusion that Track 3 with its prospective attribution and two-sided risk should also be show precedence. Track 2 meets the risk criteria; however, we recognize the operational difficulties of retrospective attribution. CMS should seek to overcome them and put a placeholder in the regulation that indicates that principally Track 2 should be given precedence once attribution timing can be overcome. By implementing these proposals CMS sends a very clear signal that they are rewarding risk taking. Many ACOs have publicly expressed concern over going to two-sided risk due to the uncertainty of the interaction between the ACO and the EPM. Adopting this proposal would eliminate that uncertainty.

Principle 3: Encourage Collaboration

The most powerful tool available to create value is for EPM participants and ACO participants to come together in ways that match their local health care environment, each bringing their own strengths and creating the maximum value possible. These private collaborations should be encouraged and celebrated. CMS can encourage such collaboration in two ways. First, removing both real and perceived barriers to collaboration. The perception that a collaboration might run afoul with law or regulation is just as paralyzing as the reality that it does. Second, CMS can lead research and demonstration efforts to attribute savings across models. The most immediate step CMS can take is to open up the data on BCPI and CJR as it has on the ACO side. An ACO style public use file on BCPI participants and CJR participants would be immensely beneficial to researchers seeking to accurately attribute savings across models. As long as CMS keeps the financial and quality information about individual participants in the BCPI and CJR programs secret, cross model research will remain very difficult and ACOs and others will, rightly or wrongly, wonder whether the secrecy is hurting them financially.

Specifically, we support the Taskforce’s recommendation for CMS to finalize its proposal to make all APM entities potential EPM collaborators.

Thank you very much for your consideration as we move together through this exciting time in healthcare. Please feel free to follow up with me or Travis Broome (travis@aledade.com) if you or your staff have questions or would like to explore these positions further