IHPC has responded to an RFI from the Centers for Medicare and Medicaid Services, CMS, on the issue of the future of the CMS Innovation Center, known as CMMI
CMMI was created by the Affordable Care Act to fund the development of new models of payment that would ultimately reduce the costs of healthcare in the U.S., at least that portion of it paid for care delivered through Medicare and Medicaid. The initial funding for this ambitious initiative was $10 billion. CMMI developed categories of clinical models through which it thought savings could be gained, through risk-sharing and other methods. In 2016 CMS presented the most important adjustment to its payment structure since Medicare was established, declaring that it would start to reimburse providers for value, rather than fee-for-performance.
The Innovation Center was created to assess, fund and underwrite payment models that serve its Medicare and Medicaid beneficiaries. Many score of models have been initiated since in recent years. But rarely have these models included integrative clinical centers or practitioners.
CMMI depends on stakeholders to come forward with applications for models, but because of the historic chasm between CMS and the integrative clinical community — despite its adoption by conventional systems in recent years — few integrative centers have made application to participate in its Alternative Payment Models (APM) program. This is due to the sustained uncertainty as to how even licensed practitioners who provide services that are “not usually paid for” (acupuncture, massage therapy, tai chi, yoga, etc.) can effectively participate to achieve CMS’ ambitious cost-saving programs. And that remains to be determined.
(Click the image of the letter for the PDF version.)
In its response to the CMS RFI, IHPC cited its mission: “Eliminating barriers to health” and noted:
The remaining and over-arching barrier that CMS can directly resolve is the inequitable status of reimbursement for services provided by state-licensed integrative providers, despite long-standing patient demand and robust clinical outcomes.
The letter, signed by IHPC Chairman Len Wisneski (at right), set out the summary of the cost-effectiveness research that IHPC compiled and published in 2015, “Integrative Health and Medicine: Today’s Answer to Affordable Healthcare”.
The letter also noted the important affirmation on the role that integrative non-pharmacologic pain treatment options have attained in the last several years, quoting from the President’s Commission on Combating Drug Addiction and the Opioid Crisis, released in November:
“The Commission recommends CMS review and modify rate-setting policies that discourage the use of non-opioid treatments for pain, such as certain bundled payments that make alternative treatment options cost prohibitive for hospitals and doctors, particularly those options for treating immediate post-surgical pain”
The letter also points out the important roles that integrative practitioners have assumed in primary care as the nation faces a primary care physician shortage; in group visits that Medicaid already funds; and in state innovation projects. It also requests that CMMI ensure that if necessary, integrative practitioners and clinical programs are granted waivers to ensure that payment for services is equitably distributed.
In its announcement of the RFI CMS said it may or may not respond to submitted recommendations.