August 16, 2018
Physician-Focused Payment Model Technical Advisory Committee
c/o Assistant Secretary for Planning & Evaluation
200 Independence Ave. SW.
Washington, DC 20201
Thank you for the opportunity to provide input on the Physician-Focused Payment Model Technical Advisory Committee (PTAC) requirements, process for providing initial feedback on proposals for Advanced Alternative Payment Models (AAPMs).
The National Committee for Quality Assurance (NCQA) is greatly interested in developing an AAPM proposal and is discussing this with medical specialty societies, health systems and states who share our interest. We are closely tracking PTAC’s thoughtful deliberations, as well as the Department of Health & Human Services’ (HHS) detailed responses to PTAC’s recommendations. We also strongly support Bipartisan Budget Act of 2018 provisions authorizing PTAC to provide initial feedback on proposed models. However, the process for providing initial feedback described in your May 15 document on “Implementing New Authority Provided by the Bipartisan Budget Act of 2018” may be too restrictive. We suggest the following improvements.
First, you should not restrict feedback to stakeholders who have submitted written proposals that meet PTAC’s existing proposal completeness criteria. The PTAC written proposal template is quite detailed, specific and lengthy. It is difficult to complete given the many substantial unanswered questions about what PTAC and/or HHS would accept on key issues such as performance measurement, payment models and evaluation. Lack of clarity on acceptable payment models in particular is inhibiting specialty societies from partnering with us on that aspect of a proposal. You also should not restrict PTAC members from suggesting potential ways to address shortcoming or having informal, individual discussions with AAPM model developers. Advice on how to address shortcomings is precisely what model developers need from initial feedback, and informal discussions between PTAC’s eminently qualified members and model developers could be invaluable to both.
The initial feedback process instead should be as informal, collegiaAl and iterative as possible in order to achieve everyone’s shared goal of a broad and strong array of AAPMs that reward value, improve quality and contain costs. PTAC and HHS also should provide more detailed descriptions on performance measures, payment models and evaluation that might be acceptable to guide model developers now inhibited from submitting proposals because of the “black box” on these issues.
Thank you again for the opportunity to comment. If you have any questions, please contact NCQA Director of Federal Affairs, Paul Cotton, at (202) 955-5162 or firstname.lastname@example.org.
Michael Barr, MD
Executive Vice President