In a letter to the Health Care Payment and Learning Action Network’s (LAN), PIPC applauds revisions made in the second draft of their Alternative Payment Model (APM) framework, while also raising concerns about the process and timeline to provide input. In the letter PIPC supports the fact that the new draft does not rely on cost effectiveness reports as a pillar for defining patient-centeredness in APMs. Additionally, PIPC strongly supports revisions made to move beyond damaging cost-effectiveness thresholds, and appreciates LAN's recognition of the importance of considering the risk of unintended consequences in APM design.
Despite the support for these changes, PIPC notes that the LAN must recognize the need for realistic timeframes for comments, particularly from patients, and the need to reach out even beyond its affinity groups and committees to educate a broader scope of patients and providers about this work and its implications for patient care. In the letter, PIPC expresses concerned that the lack of transparency related to the LAN’s operations has led to its isolation from many patient and provider communities that must have a seat at the table if its recommendations are to implemented effectively. As the LAN moves into its implementation phase, PIPC notes that it is imperative to correct these shortcomings of its process for its recommendations to have the support of the patients and people with disabilities that are served by health systems.
| PIPC LAN AMP Comments |