PIPC Submits Comments to CMMI on Listening Session on Incorporating Beneficiary Perspectives into Model Testing, Implementation, and Evaluation
In a letter to the Center for Medicare and Medicaid Innovation (CMMI), the Partnership to Improve Patient Care (PIPC) offered comments on CMMI's Listening Session entitled "Incorporating Beneficiary Perspectives into Model Testing, Implementation, and Evaluation." PIPC Chair Tony Coelho applauded CMMI Director Liz Fowler for conducting the listening session, noting that PIPC looks forward to working with the Health Care Payment and Learning Action Network (LAN) to convey the importance of beneficiary perspectives and prioritize best practices that focus on patient-centered outcomes. PIPC also called on CMMI to establish a clear process for engagement with patients and people with disabilities.
In a letter to the Innovation and Value Initiative (IVI), the Partnership to Improve Patient Care (PIPC) submitted comments on IVI's draft model protocol on major depressive disorder (MDD). The letter notes that, as designed, the model is unlikely to be able to address the issue of treatment heterogeneity, suggesting that IVI broaden the question of how to estimate the accrual of "marginal value" from new therapies. PIPC also strongly encouraged IVI to cease using of the quality-adjusted-life-years metric (QALY) in its models.
In a letter to the Department of Health and Human Services (HHS), Partnership to Improve Patient Care (PIPC) Chair Tony Coelho provided feedback on the Notice of Benefit and Payment Parameters 2023 Proposed Rule. The letter stresses that: (1) plans should not be permitted to reference the discriminatory quality-adjusted-life-years (QALY) metric; (2) research meets the standards of patient-centeredness; and (3) full transparency should be required regarding sources used in decision making.
In a letter to the Patient-Centered Outcomes Research Institute (PCORI), the Partnership to Improve Patient Care (PIPC) offered feedback on PCORI's proposed research agenda. In the letter, PIPC Chair Tony Coelho doubled down on his recommendation that PCORI engage in direct outreach to organizations representing patients and people with disabilities in its forthcoming research efforts, noting that PCORI must be more specific and clear with respect to its methodologies. The letter also stresses that PCORI should work with experts that do not view the discriminatory quality-adjusted-life-years (QALY) metric as the "gold standard" for value assessment in health care.