Changes to CMMI Models: Tracker
The Center for Medicare and Medicaid Innovation (CMMI) was established a decade ago under the Affordable Care Act to test innovative health care payment models that might improve the quality of care or decrease expenditures in the Medicare and Medicaid programs. The quantity of models has led CMMI critics to claim “model fatigue” with the collection of overlapping models and tracks within models. Further, with a change in administration, it is inevitable that the new Biden administration will seek to tweak, delay or even discontinue some models. In the table below, Faegre Drinker tracks recent changes to CMMI models and will continue to monitor future changes.
| Model Name | Summary | Nature of Action | Summary | Approx. Date of Action |
|---|---|---|---|---|
| Medicare Part D Payment Modernization Model | Tests how changes in Part D benefit design and incentives would affect overall Part D prescription drug spending and beneficiary out-of-pocket costs. | Termination | With only two drug plans participating in the model, CMS opted to terminate the model altogether. The model will conclude on December 31, 2021, and CMS will not proceed with testing the Model in CY 2022-CY 2024. | May 6, 2021 |
| Comprehensive Care for Joint Replacement Model | Comprehensive Care for Joint Replacement Model | Extension and revised scope | CMS announced a 3-year extension of the model through the end of 2024. CMS also extended the 2020 performance year for three months, through March 31, 2021. The model now also includes outpatient hip and knee replacements. | April 29, 2021 |
| Community Health Access and Rural Transformation (CHART) Model | Tests whether development of provider and community partnerships through operational flexibilities will improve health care delivery in rural areas. | Delay | CMS delayed the application period for the ACO Transformation Track from Spring 2021 to Spring 2022. CMS did not announce an updated start date. | March 30, 2021 |
| Medicare Part D Payment Modernization Model | Tests how changes in Part D benefit design and incentives would affect overall Part D prescription drug spending and beneficiary out-of-pocket costs. | Revised Scope | Two Part D formulary flexibilities built into the model—with respect Protected Classes and number of drugs per therapeutic class—are removed from the model. CMS also is not moving forward with removing downside risk for 2022. | March 16, 2021 |
| Kidney Care Choices | Enables ESRD-focused accountable care organizations to manage care for beneficiaries with CKD 4 and ESRD. | Delay | The model was supposed to begin January 2021 and is now delayed until January 2022. | March 8, 2021 |
| Community Health Access and Rural Transformation (CHART) Model | Tests whether development of provider and community partnerships through operational flexibilities will improve health care delivery in rural areas. | Delay | CMS announced theNotice of Funding Opportunity (NOFO)for the Community Transformation Track in September 2020. The application deadline is extended to May 11, 2021. | March 5, 2021 |
| Primary Care First – Seriously Ill Population Track | Offers innovative payment structure to support the delivery of advanced primary care by prioritizing the doctor-patient relationship and enhancing care for patients with complex chronic needs. | Delay | This model track was supposed to begin April 2021. The Biden administration announced that the model is under review. | March 5, 2021 [Note: model was previously delayed] |
| Direct Contracting – Geo Track | Tests whether a geographic-based approach to care delivery and value-based care can improve health and reduce costs for Medicare beneficiaries across an entire geographic region. | Delay | This model track was supposed to begin January 2022. The Biden administration announced that the model is under review. | March 2, 2021 |
| Home Health Value-Based Purchasing Model | Designed to support greater quality and efficiency of care among Medicare-certified Home Health Agencies (HHA) across the nation by rewarding HHAs for high-quality care that saves Medicare money. | Nationwide expansion and revised scope | CMS announced that it intends to expand HHVBP through rulemaking beginning no sooner than Jan. 1, 2022. | January 8, 2021 |
| Most Favored Nation Model | CMS pays no more for high-cost Part B drugs than the price that drug manufacturers receive in other similar countries | Delay/Termination | The U.S. District Court for the Northern District of California issued a nationwide preliminary injunction in Biotechnology Innovation Organization v. Azar, No. 3:20-cv-08603, which preliminarily enjoins HHS from implementing the Most Favored Nation Rule.Given this preliminary injunction, the MFN Model will not be implemented without further rulemaking. | December 28, 2020 |
| Radiation Oncology Model | Tests whether bundled payments for radiotherapy episodes of care reduces Medicare expenditures while preserving or improving quality of care for beneficiaries. | Delay | Congress prohibits model from beginning before January 1, 2022. | December 27, 2020 |
This table is updated monthly. Last revision: May 7, 2021
The material contained in this communication is informational, general in nature and does not constitute legal advice. The material contained in this communication should not be relied upon or used without consulting a lawyer to consider your specific circumstances. This communication was published on the date specified and may not include any changes in the topics, laws, rules or regulations covered. Receipt of this communication does not establish an attorney-client relationship. In some jurisdictions, this communication may be considered attorney advertising.