PEPC was pleased to respond to the Centers for Medicare and Medicaid Services’ (CMS) request for information (RFI) on an Episode-Based Payment Model. Our comments focus on specific considerations for the CMS Innovation Center to ensure that it develops future episode-based payment models that leverage past physician-led in similar models and reflects the unique clinical and financial circumstances of independent physicians and practices. It is critical that a new model does not inadvertently incentivize further consolidation by favoring larger physician practices and systems. We urge CMS to develop a model that is voluntary for all providers, including accountable care organizations (ACOs), and recognizes that every provider is unique and will require different tools to succeed.
To read the full response, click here.