The Difficulty in Making A Thousand Flowers Bloom

Politico included a recent article on “Why Moving on Delivery Reform is so Difficult” that described the dilemma facing Henry Ford  Health System, which resulted in a decision to withdraw their application for the Medicare ACO program. They would rather focus on participating in private sector initiatives, which offer more predictability and flexibility than demonstrations designed by CMS. 

It has been hard to follow the many starts and stops from the Center for Innovation as they are rolling out ACA funding for delivery reform demonstrations.  CMS has many more hurdles in initiating demonstration programs than private payers. For example, the process needs to be competitive and give all parties a chance to be considered. The demonstration design needs to address the policy questions, but also produce data for an objective evaluation.  There is a large bureaucracy involved in clearing politically sensitive projects and it always takes longer than expected.  And another complexity is that operational support depends on offices and staff outside the Innovation Center.

Two recommendations would improve the process for potential applicants who have limited resources and leadership time to make a commitment to a new way of doing Medicare business:

First a master schedule and work plan would  be helpful so that applicants would know the range and timing of funding opportunities. For example, the recently released Primary Care Demonstration was unexpected and seemed to be a revival of the medical home demonstration that CMS put on the back burner last year.  The bundled payment demonstration was of interest to many of the ACO applicants but the application process partially overlapped the Pioneer ACO demonstration process. 

It would also be helpful to know all of the requirements in advance of submitting an application.  As others have suggested, streamlining the number of quality reporting measures and making them more consistent with core measures used by the private sector would make the Medicare demonstrations more attractive.