CMMI’s Ability to Innovate Should Be Protected and Championed

We are former senior officials of the Centers for Medicare and Medicaid Services for Republican and Democratic administrations who share a deep commitment to transitioning U.S. health care to a system where value-based payment and care delivery are ubiquitous. 

To this end, we strongly believe the Center for Medicare and Medicaid Innovation remains an important institution that drives local markets to improve the health care system and deliver better care at lower cost. However, H.R. 5741 would restrict CMMI’s statutory authority in ways that would severely impede the industrywide transition away from fee-for-service, including our ability to effectively implement value-based payment models within our respective private-sector organizations. 

As members of the Health Care Transformation Task Force, we recognize there are opportunities to improve upon the CMMI approach but warn that reintroducing legislative approval requirements or imposing judicial review on the Medicare demonstration process would not be meaningful reform. It would instead be a marked retreat from consequential and timely innovation.

CMMI is a critical and necessary driver to achieving the bipartisan Medicare Access and CHIP Reauthorization Act’s goal of moving Medicare providers into advanced alternative payment models. The Innovation Center operates 12 of the 13 models qualified as Advanced APMs for performance year 2020. 

CMMI’s activities have also accelerated the adoption of value-based payment approaches in the commercial market, magnifying the impact of its demonstration investments through multipayer models and helping providers build capacity to take on risk in private contracts. Placing unnecessary administrative barriers on CMMI’s ability to test and expand effective models would be an unwelcome step back for the entire industry and effectively an endorsement of fee-for-service.

The way that the Innovation Center is structured and carries out its work is subject to meaningful congressional oversight and public input. CMMI has latitude to test health care delivery and payment models in Phase One demonstrations. 

If a Phase One model is found to reduce (or not increase) program spending while improving (or not decreasing) the quality of care for Medicare and Medicaid beneficiaries, the secretary may expand the model under Phase Two but must do so by going through notice and comment rulemaking.  In those cases, the CMS Actuary’s certification to support model expansion is also made public. 

CMMI also follows a public rulemaking process for Phase One models for which participation is mandated. This means that Congress and the public will always have an opportunity to provide input and express approval or withhold support for a proposed model expansion or mandate.    

Prior to CMMI, policymakers were concerned by the untimeliness of Medicare’s research activities under traditional demonstration authority and other administrative barriers it placed on the agency’s ability to implement urgently needed policy innovations. In its 2009 report to Congress, the Medicare Payment Advisory Commission noted: “Medicare needs to be able to conduct demonstrations and implementation in a rapid cycle to make fundamental payment system reforms.” The commission also advised Congress to allow successful models to become program policy without further congressional action and supported the Phase One expansion criteria outlined above.

Congress also exercises oversight of CMMI in other ways. The Innovation Center is required to and does submit a report to Congress on its activities every two years, including description of the number of beneficiaries impacted by the demonstrations, expenditures obligated and formal evaluation results. 

Annual evaluation results on each model are made public in both comprehensive and “at-a-glance” summary formats. CMMI leadership has also provided timely testimony and responses to congressional inquiries on a regular basis. 

While much work remains to achieve a truly value-based health care system, the progress that the industry has made working in partnership with the Innovation Center argues for staying the course on CMMI’s most fundamental authorities to innovate. The changes to CMMI’s authorities contemplated in H.R. 5741 would jeopardize timely and effective testing and put at risk millions of dollars of capital that willing providers and health plans have invested in CMMI models. Congress should resist efforts such as H.R. 5741 to alter the construct under which the Innovation Center currently operates, which would likely hamstring a leadership effort that many see as critically important to the progression to value-based care.  

Our nation needs a health care system that delivers better quality, better experience and lower costs. Individuals and families want the system to improve at a much faster rate. CMMI is critical to achieving this goal for the people of our country.


Sean Cavanaugh is the chief administrative officer for Aledade Inc., and a former CMS deputy administrator and director of the Center for Medicare. 

Patrick Conway, M.D., is the former CEO of Blue Cross Blue Shield of North Carolina, and he previously served as a former CMS chief medical officer, deputy administrator and director of the Center for Medicare and Medicaid Innovation. 

Richard Gilfillan, M.D., is the former chief executive officer of Trinity Health, and he previously served as the director of the Center for Medicare and Medicaid Innovation. 

Hoangmai Pham, M.D. is the vice president of provider alignments solutions at Anthem, and a former chief innovation officer at the Center for Medicare and Medicaid Innovation. 

Rahul Rajkumar, M.D., is the chief medical officer of Blue Cross Blue Shield of North Carolina and a former deputy director of the Center for Medicare and Medicaid Innovation.

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