HCI3 Update from the Field – Newtown, CT
18 months and counting – that's the amount of time CMS has to launch the national episode of care pilot. In a new report released earlier this week by the Center for American Progress, Harriet Komisar, Judy Feder and Paul Ginsburg outline some important recommendations for CMS to make this pilot a true success. At a meeting on Monday to announce this report, CAP invited Nancy-Ann De Parle, and Rick Gilfillan from the Administration to discuss challenges and opportunities of implementing EOC payment. Rick used the opportunity to outline options under consideration by the CMMI to accelerate the launch of EOC payment pilots:
- First, and quickly, the "easy" stuff – expansion of the ACE demo to the rest of the nation, and possible introduction of post-acute acre bundles – in order to leverage existing CMS infrastructure.
- Second, linking acute and post-acute into a single episode – we're already doing this in the private sector (e.g. IHA and PROMETHEUS) – which is more complex for CMS to administer because they don't yet have the claims engines to support this type of EOC payment.
- Third, chronic care episodes – because they need the public domain episode definitions, which won't be ready for another year, and they need beefed up operations, which will take some time and investment.
What this means to you – finally, the time is at hand and the volume of FFS payments emanating from CMS is poised to decrease. The expansion of ACE to the rest of the country is a no-brainer and, frankly, not an innovation since it's already in play. It's simply the scaling of an existing demo and it should have been done six months ago. Post-acute care EOC payments are, from my perspective, an unnecessary step. It's a provider-centric view of an episode, not a patient-centered one. In addition, it's not clear who would be responsible for readmissions. Likely no one, which is really really bad. So to innovate (and it's not really an innovation) CMMI should focus on bundling acute and post-acute hospital-based episodes, and do it quickly. After all, we're already doing it. Chronic care episodes are where the real savings lie and everyone knows it. Yes there are challenges, but isn't that what the $1billion-a year-funded-CMMI is supposed to tackle? Plus, as our toolkit shows, we've pretty much broken down the barriers. So let's get ready to move with temerity, not timidity.
Francois de Brantes
Health Care Incentives Improvement Institute, Inc.