In a letter to Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma, Partnership to Improve Patient Care (PIPC) Chairman Tony Coelho criticized the HHS Notice of Benefit and Payment Parameters for focusing on cost effectiveness and creating a national default definition of essential health benefits. While the notice proposes flexibility for states in defining essential health benefits, Chairman Coelho noted that the Notice of Benefit does not focus on how to align payment with achieving care tailored to individual patients. "It fluctuates between a policy of “anything goes” by allowing states increased flexibility in defining their benefit packages, and a “one-size-fits-all” policy relying on cost effectiveness reports to determine patient access to care," wrote Chairman Coelho. "​To truly put patients first, CMS should instead embrace this as an opportunity to change the culture of our payment system to be patient-centered."

In a letter to Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma, Partnership to Improve Patient Care (PIPC) Chairman Tony Coelho submitted comments on behalf of PIPC in response to the Request for Information on a new direction to promote patient-centered care at the Center for Medicare and Medicaid Innovation (CMMI). Chairman Coelho urged CMS to implement "concrete reforms" in four key areas, including: (1) Defining a clear, consistent process for engaging patients and other stakeholders in development and implementation of CMMI evaluations; (2) Defining and adopting detailed criteria for patient-centeredness in CMMI evaluations; (3) Building on and strengthening the patient safeguards articulated in the RFI and; (4) Pursuing demonstrations that embody these reforms and put patients at the center of the health care​.

In a letter to Department of Veterans Affairs Secretary David Shulkin, over 40 representatives of veterans, patients and people with disabilities expressed concern regarding the recently announced collaboration between the Institute for Clinical Economic Review (ICER) and the Department of Veterans Affairs (VA) Pharmacy Benefits Management Services office.  They cautioned Secretary Shulkin about ICER's quality-adjusted-life-year (QALY) metric, citing its "potentially discriminatory" impact on people with disabilities and serious chronic conditions. 

In a letter to acting Health and Human Services Secretary Eric Hargan, Partnership to Improve Patient Care (PIPC) Chairman Tony Coelho expresses serious concerns with the proposal in the Massachusetts 1115 waiver amendment that would potentially limit access to new and innovative drug therapies. Chairman Coelho suggests to Secretary Hargan that the ​State of Massachusetts look to entities such as PCORI for insights on how to measure comparative effectiveness of treatments in real world situations. "We encourage states like Massachusetts to invest in the development of shared decision-making tools that reflect how treatments impact patients in real-world circumstances, so that patients are able to choose the treatment that is most effective for their individual needs," wrote Chairman Coelho. "You have an opportunity to partner with patients and people with disabilities to determine the outcomes that matter most to them in their treatment, measure those outcomes, and translate that information into tools that ensure patients get the right care at the right time."

In a letter to Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma, Partnership to Improve Patient Care (PIPC) Chairman Tony Coelho submitted comments on the proposed cancellation of the episode payment models. In the letter, Chairman Coelho applauded CMS for prioritizing provider participation in voluntary models. "I was pleased to learn that the Centers for Medicare and Medicaid Services proposed to cancel the Episode Payment Models (EPMs) and Cardiac Rehabilitation (CR) incentive payment model and to rescind the regulations governing these models," wrote Chairman Coelho. "It is not because I do not think the agency should test new payment models.  It is simply because, based on input from patients and providers, these models required more work to get it right, and certainly were not seen as sufficiently evaluated to be mandatory."

In a letter to Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma, Partnership to Improve Patient Care (PIPC) Chairman Tony Coelho expressed his concerns about the latest proposal to the Medicare Shared Savings Program to remove the requirement to submit supporting documentation related to patient-centeredness in their applications. "We are concerned that CMS would propose to remove these requirements and accept attestation in their place," said Chairman Coelho.  "Although we understand that CMS is attempting to lessen the burden on ACO applicants, we believe that it is imperative that ACOs be held to the highest possible standard for patient-centeredness."

In a letter to Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma, Partnership to Improve Patient Care (PIPC) Chairman Tony Coelho urges a focus on the patient voice when it comes to improving the Quality Payment Program. "Under the proposed rule, it is also important to recognize the reliance on providers to deliver patient-centered care, and to practice in a manner consistent with the measures of success adopted by the program," wrote Chairman Coelho. "Being truly patient-centered will require working closely with providers to ensure that the Quality Payment Program’s complexity does not detract from individualized patient care."

​In a letter to Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma, Partnership to Improve Patient Care (PIPC) Chairman Tony Coelho stressed the agency to engage stakeholders -- particularly patients -- when it comes to reforming the Affordable Care Act and improving healthcare choices to empower patients. "In this age of personalized medicine, we strongly believe that the value of health care is defined by achieving outcomes that matter to patients in our health care system, not by imposing policies that drive one-size-fits-all treatment decisions," said Chairman Coelho. 

Value assessment in general, and the use of cost-effectiveness in particular, is receiving renewed interest as a tool for controlling health care spending. Currently, the most common method for determining incremental cost-effectiveness of healthcare interventions is based on a calculation of quality-adjusted-life-years (QALYs). While the model has a basic appeal for making population-level decisions (by reducing patient populations to single, aggregate numeric values), it also poses several significant concerns from the vantage point of patient-centeredness and efforts to preserve access to needed care for individual patients and people with disabilities.  Of particular concern to me are the implications of use of QALYs for discrimination against people with disabilities, and its conflicting goals from the goals of personalized medicine.

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.