CMS’ proposed Part B Drug Payment Model would be run by the Center for Medicare and Medicaid Innovation (CMMI). CMMI was set up to test new payment and delivery models and is required to evaluate each model to understand the impact on quality of care (including patient outcomes) and changes in program spending. This evaluation – and ongoing monitoring for unintended effects – is very important to ensure that Medicare patients are not harmed by any changes to the Medicare program.
Discern Health identified several gaps and risks in the Part B Drug Payment Model design, including:
- The mandatory participation requirement, which could disrupt care delivery that is already complex for many patients;
- A lack of necessary quality measures available to capture patient-reported quality outcomes;
- A failure to evaluate the impact on outcomes, such as survival and quality of life; and
- The broad scope of the model, which will necessitate immense resources for adequate monitoring and evaluation.
The findings of the brief are concerning, particularly because the unprecedented nationwide, mandatory design of the Model increases the potential for unanticipated negative effects for Medicare patients. These concerns that the Part B Drug Payment Model could have serious consequences for patient access to appropriate care were raised by over 300 stakeholders. The apparent lack of safeguards to protect patient access to care is just one more reason stakeholders are calling for CMS to withdraw the proposal.