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
Among the highlights of PIPC's comments to CMS:
- Patient Advisory Panel – A broad Patient Advisory Panel within CMMI would be a first step to ensure new payment models are aligned with care that patients’ value. A Patient Advisory Panel could provide guidance to CMMI in identifying the key areas that would benefit from patient input, including APM development, model design features that will promote effective patient engagement, and metrics (e.g., patient-centered quality measures and other tools) on which to assess the success of these efforts.
- Direct Outreach to Patients – Achieving meaningful input from beneficiary stakeholders, particularly patients, people with disabilities, and their families, is a continuous process that requires targeted strategies in addition to regulatory notice and comment. This means conducting outreach to subgroups of organizations representing patients and people with disabilities that are directly impacted at the outset to determine what innovative models may be needed to improve care for particular patient populations.
- Measure Outcomes that Matter to Patients – To promote patient-centered care, payment systems must have incentives to capture patient preferences and to demonstrate those preferences are driving care decisions. At the same time, it is important to prioritize the measures to which providers are held accountable so that they truly reflect outcomes that matter patients and do not place undue administrative burdens on providers.
- Be Accountable for Patient Input – As part of the process for obtaining public input, CMS and CMMI should note where they have incorporated stakeholder feedback in the final framework of a demonstration program, and provide a rationale for instances in which stakeholder feedback has not been accepted, similar to the current requirements in place for notice-and-comment rulemaking.
- Advance Shared Decision-Making – PIPC urges policymakers not to lose focus on the building blocks for patient-centered health care incorporated into the early phases of evidence development, translation and implementation, all the way through to the design and implementation of new payment and delivery reform models. In this way, our health care system will be built to improve health outcomes by identifying the treatments that work best for individual patients.
| pipc_macra_comments.pdf |