Today, the Partnership to Improve Patient Care (PIPC) submitted comments on the implementation of the Merit-based Incentive Payment System (MIPS), Promotion of Alternative Payment Models, and Incentive Payments for Participation in Eligible Alternative Payment Models passed as part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Since its founding, PIPC has been at the forefront of patient-centeredness in comparative effectiveness research (CER) – both its generation at the Patient-Centered Outcomes Research Institute (PCORI), and its translation into patient care. Having driven the concept of patient-centeredness in the conduct of research, PIPC looks forward to bringing the patient voice to the discussion of how to advance patient-centered principles throughout an evolving health care system
The U.S. has made significant progress in advancing patient-centeredness over the last several years. The progress we have made is the fruit of a movement that spans several decades, and PIPC is proud to have lent its voice to this effort. Advances in policy such as the authorization of PCORI in 2010 and Patient-Focused Drug Development at the Food and Drug Administration (FDA) highlight the recognition by policymakers that patients should not be in the back seat. Instead, patients should be driving research, and given the recognition that they are capable of translating patient-centered research into health care decision-making.
At the same time, much work remains to be done. While most health policy experts agree on the notion of developing a “patient-centered health care system,” we do not yet have a delivery system that entirely incorporates or is modeled on delivering patient-centered health care. PIPC promotes policies that apply patient-centered principles throughout the health care system – from development of evidence (i.e. PCORI) to the design of new payment and delivery reforms (i.e. alternative payment models (AMPs)).We strive to raise awareness about the value of well-designed comparative clinical effectiveness research, the important role of continued medical innovation as part of the solution to cost and quality challenges in health care, and the importance of shared decision-making between patients and providers that empowers truly patients to play a more active role in their own healthcare decisions. PIPC members, representing a diverse, broad-based group of health care stakeholders, are dedicated to working together to promote giving a voice to patients, giving choice to patients, and advancing value for patients.
Implementation of MACRA provides an opportunity to advance a health system that meets the principles of patient-centeredness and therefore empowers and activates patients in their own care. In furtherance of this goal, PIPC provides the following broad recommendations for payment and delivery of healthcare:
This Request for Information (RFI) is a positive first step to receive input from stakeholders related to the development of policies to implement MIPS, promote APMs, and implement incentive payments for participation in eligible APMs. Nevertheless, we would emphasize that achieving meaningful input from beneficiary stakeholders, particularly patients, people with disabilities, and their families, is a continuous process that requires targeted strategies beyond a regulatory notice and comment. We believe such input from the beneficiaries whose care relies on getting this right will be vital to achieving the statute’s goals. Ultimately, the transition to value-based health care must look at value from the perspective of patients served by the system of care.The full comments submitted to the Centers for Medicare and Medicaid Services are available below.
At the same time, much work remains to be done. While most health policy experts agree on the notion of developing a “patient-centered health care system,” we do not yet have a delivery system that entirely incorporates or is modeled on delivering patient-centered health care. PIPC promotes policies that apply patient-centered principles throughout the health care system – from development of evidence (i.e. PCORI) to the design of new payment and delivery reforms (i.e. alternative payment models (AMPs)).We strive to raise awareness about the value of well-designed comparative clinical effectiveness research, the important role of continued medical innovation as part of the solution to cost and quality challenges in health care, and the importance of shared decision-making between patients and providers that empowers truly patients to play a more active role in their own healthcare decisions. PIPC members, representing a diverse, broad-based group of health care stakeholders, are dedicated to working together to promote giving a voice to patients, giving choice to patients, and advancing value for patients.
Implementation of MACRA provides an opportunity to advance a health system that meets the principles of patient-centeredness and therefore empowers and activates patients in their own care. In furtherance of this goal, PIPC provides the following broad recommendations for payment and delivery of healthcare:
- Provide a meaningful voice to patients. Policymakers should establish formalized mechanisms that provide a meaningful voice to patients throughout the healthcare system.
- Prioritize policies that promote patient-centeredness and ensure new payment and delivery models do not define success as simply meeting financial targets or promote a “one-size-fits-all” approach to cost-containment.
- Catalyze the expansion of available quality measures and ensure they are appropriately incentivized in health systems. Policymakers should recognize the need to improve the patient-centered infrastructure for measuring and rewarding improved health outcomes. There are significant gaps in quality measurement that will require expanded support for measure development and endorsement.
- Foster informed choices from the range of clinical care options through shared decision-making, transparency of the incentives (financial and otherwise) that drive care decisions, and by empowering patients with accessible, understandable evidence.
- Support patient access to high quality individualized care
This Request for Information (RFI) is a positive first step to receive input from stakeholders related to the development of policies to implement MIPS, promote APMs, and implement incentive payments for participation in eligible APMs. Nevertheless, we would emphasize that achieving meaningful input from beneficiary stakeholders, particularly patients, people with disabilities, and their families, is a continuous process that requires targeted strategies beyond a regulatory notice and comment. We believe such input from the beneficiaries whose care relies on getting this right will be vital to achieving the statute’s goals. Ultimately, the transition to value-based health care must look at value from the perspective of patients served by the system of care.The full comments submitted to the Centers for Medicare and Medicaid Services are available below.
| pipc_macra_proposal_comments.pdf |