Today, the Partnership to Improve Patient Care (PIPC) submitted comments on the Alternative Payment Model (APM) Framework Draft White Paper composed by the Health Care Payment and Learning Action Network (LAN). In the comments, PIPC expresses our belief that a few foundational elements must be in place for an APM framework to be successful. First, new payment models must have the tools to appropriately risk adjust so that bundled, population-based or capitated payment models do not inappropriately restrict access to care for chronically ill and disabled patients. Second, quality measures must be developed and implemented that capture outcomes that matter to patients so that “quality” and “value” are based on patient needs, preferences and outcomes. Third, decision aids must exist and be used that provide patients with unbiased access to their treatment options and the impacts of those treatments on outcomes that matter to patients so that shared decision-making is meaningful. Lastly, a constant feedback loop must exist to identify in real time the impact of new payment models on access to care, particularly for vulnerable populations.
On the issue of quality, PIPC agreed with the white paper’s assessment that quality indicates that patients receive appropriate and timely care that is consistent with evidence-based guidelines and patient goals, and that often generates positive patient outcomes. 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. The Partnership believes patients and providers should be at the forefront of this process.
Overall, PIPC is concerned about the pace at which alternative payment models are being promoted and expanded, potentially in the absence of appropriate risk adjusters, quality measures, decision aids, and feedback loops. We urge a strong focus on developing this foundation in order to thoughtfully advance alternative payment models that achieve outcomes that matter to patients.
In furtherance of this goal, PIPC provides the following broad recommendations for payment and delivery of healthcare.
Overall, PIPC is concerned about the pace at which alternative payment models are being promoted and expanded, potentially in the absence of appropriate risk adjusters, quality measures, decision aids, and feedback loops. We urge a strong focus on developing this foundation in order to thoughtfully advance alternative payment models that achieve outcomes that matter to patients.
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 development and endorsement of meaningful 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.
| pipc_lan_comments_-_apm_framework.pdf |
