PEPC Comments on CMS Direct Provider Contracting RFI

The Partnership to Empower Physician-Led Care (PEPC) is pleased to submit our comments on the Request for Information Regarding Direct Provider Contracting. PEPC is a coalition of stakeholders supporting independent physicians and practices in the movement to value-based care.

General Comments

PEPC encouraged the Centers for Medicare & Medicaid Services (CMS) to
prioritize physician‐led alternative payment models, including physician‐led accountable care organizations (ACOs) and other approaches to achieve improved outcomes for patients, greater value through lower cost of care, and the preservation of independent clinical practice. We recommended that CMS consider five principles when developing new models or refining existing approaches to value‐based care:

  1. Physicians are best positioned to drive delivery system transformation.
  2. Models should be accessible to a wide range of physicians, including physicians choosing to remain independent.
  3. New models should allow physician practices to assume appropriate financial risk for reducing costs proportional to their finances while offering greater reward over time for practices agreeing to take on more risk.
  4. Models should test a range of innovations aimed at encouraging consumers to engage in their care while not imposing substantial new administrative burdens or paperwork requirements on physician practices.
  5. Quality measures should be harmonized across new and existing models to the extent possible and CMS should use a parsimonious list of meaningful measures that reduce the burden of reporting.

Read our comment letter.

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