WHG - Roundup of Key CMMI Developments

Summary

As the Biden-Harris Administration continues to establish its health care priorities, the Center for Medicare and Medicaid Innovation (CMMI) is again emerging as a key part of how the Administration will advance its agenda. First, as a brief recap, CMMI has announced a number of delays, review periods, and other changes to ongoing and upcoming demonstration models since the new Administration has taken office. Those changes are cataloged below:

Model	Details
Community Health Access and Rural Transformation (CHART) Model	The application period for the accountable care organization (ACO) track was delayed until Spring 2022. The application period due date for the Community Transformation Track was extended to May 11, 2021.
Kidney Care Choices Model	The model was delayed until January 2022.
Primary Care First Model	The Seriously Ill Population track has been placed under review with no new start date yet announced.
Geographic Direct Contracting Model	The model has been placed under review with no new start date yet announced.
Global and Professional Direct Contracting Model	CMMI announced it no longer intends to solicit applications for new organizations interested in participating in the Global and Professional model beginning on Jan. 1, 2022.
Most Favored Nation Model	On December 28, 2020, the interim final rule was blocked through a nationwide preliminary injunction issued by the U.S. District Court of the Northern District of California. The ruling enjoins HHS from implementing the model and cannot be implemented without further rulemaking.
Radiation Oncology Model	Congress prohibited CMMI from beginning the model before Jan. 1, 2022.
Part D Modernization Model	CMMI announced it is reversing changes the previous Administration made to the model which would have loosened the Part D six protected class protections for CY 2022 of the demonstration.

More recently, the new CMMI Director Liz Fowler gave a speech to the National Association of ACOs outlining her vision for the agency under the new Administration. Briefly, she stated that CMMI would focus its efforts on models around advancing health equity at every stage of a demonstration; better serving and aligning care for beneficiaries dually eligible for Medicare and Medicaid; and lowering drug prices (potentially as a fallback if Congress does not pass drug pricing reform). Ms. Fowler also reportedly spoke to taking a more nuanced approach to providers taking on more financial risk in demonstration models, as well as increasing the number of models that feature multi-payer alignment.

Of note, the Medicare Payment Advisory Commission (MedPAC) recently voted to advance formal recommendations to the U.S. Department of Health and Human Services (HHS) that would encourage a more focused, streamlined set of CMMI models explicitly designed to work harmoniously with one another. The Commission is making these recommendations largely on the grounds that a larger and uncoordinated set of models could be diluting the ability for any one model to lower costs and improve quality. While these recommendations will pose no formal obligations on HHS, they may serve as a guidepost for how a new CMMI could think about its portfolio of models, especially as its review of current and future models continues.