WASHINGTON -- Today's meeting of the Physician-focused Payment Model Technical Advisory Committee (P-TAC) is an especially important one: it will be getting down to its main mission for the first time in its short history.
Made up of physicians and health policy experts, the P-TAC is tasked with helping the Centers for Medicare & Medicaid Services with its evaluation of advanced alternative payment models (APMs) under a brand new reimbursement structure.
The panel was formed thanks to a provision of the Medicare Access and CHIP Reauthorization Act (MACRA) -- the reimbursement structure that replaced the broadly unpopular sustainable growth rate formula (SGR) in April 2015.
Its mission is to review physician-focused payment models, also known as alternative payment models, submitted to the Department of Health and Human Services (HHS) and then to advise the department on whether the models meet the criteria established by the HHS Secretary.
At the panel's inaugural meeting in February, members addressed housekeeping concerns and core goals, such as overcoming fragmented care and ensuring that small, independent practices aren't forgotten. ()
At this week's meeting, the panel will get into the details of its mission, with presentations from the Office of the Assistant Secretary for Planning and Evaluation (ASPE) and from , acting administrator of CMS, regarding a newly proposed rule for implementing MACRA, issued last week, just in the time for the meeting.
The rule outlines potential criteria for two pathways under one Quality Payment Program: the Advanced Alternative Payment Model (APMs) and the Merit-based Incentive Payment System (MIPS). Providers who do not meet the requirements for APMs will default to the MIPS.
, P-TAC member and president and CEO of the Pittsburgh-based Center for Healthcare Quality and Payment Reform, said that the proposed rule appears to offer "a sufficiently broad window" for those developing APMs to submit them to the committee for review.
Its release in late April is also quite fortunate for the committee. Miller told ľֱ,"It's hard to conceptualize how to comment on a process unless you have at least a sense of the criteria that the proposals are going to be evaluated against."
He continued, "I think that people may be more comfortable commenting about the [APM evaluation] process now that they've at least seen what the proposed rule is."
ASPE published a proposed framework for the committee's review process for APM submissions in advance of Wednesday's meeting. The draft proposal includes three stages: proposal preparation and submission, preliminary review, and full committee review.
The draft plan also suggests that the committee will wait for a final rule to be established before announcing its request for proposals (RFP). MACRA's final rule is expected by November 2016.
Again according to the proposed plan, the RFP announcement will include a submission template along with submission instructions. ASPE's P-TAC staff will verify that proposals are complete and return those that are not within 30 days; parties will be allowed to resubmit.
Complete proposals will be given to two or three P-TAC members for preliminary review. These subgroups will draft "decision memos" summarizing key information from the submissions. Proposals that meet certain technical requirements will be received by the full committee and discussed during a public meeting.
On Wednesday, physician groups and other stakeholders will have an opportunity to comment on this suggested evaluation process. The panel, according to a , is particularly interested in the following questions:
- What should stakeholders be expected to include in [Physician-focused Payment Model] proposals? What information would be burdensome for stakeholders to produce?
- What types of technical assistance would be most useful to stakeholders in preparing and submitting PFPM proposals
- What expectations do stakeholders have regarding the timeline for the review process?
Miller noted, "This is not a public comment, just going through the motions. We're actually really interested in what people would suggest."
However, Miller stressed that the committee has no bearing on the actual APM eligibility criteria. Those are determined by the Secretary of HHS, he said. "If people want to comment on that, we're not really the right venue."