PEPC Statement on House Energy & Commerce CMMI Hearing

STATEMENT FOR THE RECORD: “Checking-In on CMMI: Assessing the Transition to Value-Based Care”

The Partnership to Empower Physician-Led Care (PEPC) is an advocacy coalition supporting value-based care to reduce costs, improve quality, empower patients and physicians, and increase access to care for millions of Americans through a competitive health care provider market. We believe that it is impossible to achieve true value-based care without a robust independent practice community. Our members include Aledade, American Academy of Family Physicians (AAFP), California Medical Association, and Medical Group Management Association (MGMA). We also have individual and small medical group supporters across the country, many of whom are independent physicians/practices and wish to remain so.

We commend the Committee for its efforts to ensure the Center for Medicare and Medicaid Innovation (CMMI) is supporting health care providers across the delivery system in transitioning to value-based care, while meeting is statutory directives of improving outcomes and/or lowering costs for patients.

Earlier this year, PEPC released a white paper highlighting the independent physician practice experience  in several CMMI models: the ACO Investment (AIM) Model, Next Generation ACO (NGACO) Model, Comprehensive Primary Care (CPC) Initiative and CPC Plus (CPC+). Through this review, PEPC found:

  • Independent practices are more agile, flexible, and timely in their implementation of care interventions. 
  • Independent practices deliver benefits of value-based care directly to patients, with higher enrollment in care management and disease management programs and directly providing acute care to attributed patients. 
  • Once a model test ends, independent practices generally sustain participation in value-based care by moving into the Medicare Shared Savings Program (MSSP) or other CMMI models. 
  • Independent practices are uniquely positioned to adapt and provide flexible care delivery in changing circumstances, such as during the COVID-19 pandemic. 

PEPC’s review also highlighted that competitive dynamics can serve as both a deterrent and accelerator for independent practices participating in value-based care efforts. For example, in the NGACO model, physician practice NGACOs were associated with significantly larger spending declines in markets with lower hospital concentration than those with higher hospital concentration. We believe that intentionally-designed models that meet the needs of independent physicians and practices can begin to level the playing field and offer a path to sustainability in a difficult landscape.

We hope you will consider these insights as Congress looks to take legislative and regulatory action to ensure CMMI is delivering on its statutory directives while supporting our nation’s independent physicians in providing high-quality, value-based care. 


Kristen McGovern

Executive Director

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