What Happened, What You Missed: May 9-13

States Regain Authority to Pay for Home Health Aides’ Insurance 

State Medicaid agencies can once again directly pay for independent home health aides’ benefits, according to a final rule the Centers for Medicare and Medicaid Services (CMS) issued Thursday.  The final rule overturns a 2019 rule that required states to pay the full Medicaid rate to home health aides, which made health coverage and other benefits more costly and created administrative barriers to enrollment.  Under the new rule, state Medicaid agencies can now allow home health aides not working with an agency to have employee benefit premiums and union dues deducted from their paychecks.  According to CMS, boosting benefits for home health workers can help address the industry’s workforce shortage.

FDA Open to Moving Up Meeting Dates on Vaccines for Young Kids

A top Food and Drug Administration (FDA) official told members of the Select Subcommittee on the Coronavirus Crisis during a May 9 briefing that the agency will move up an advisory panel’s meeting dates on vaccines for children under 6 if the FDA finishes reviewing vaccine data sooner than expected.  The briefing was convened after reports emerged that the FDA was delaying its review of COVID-19 vaccines for young kids until both Pfizer and Moderna had submitted clinical trial data.  Additionally, the subcommittee was informed that the FDA would not withhold authorization for a pediatric vaccine solely because it did not reach a 50% efficacy threshold at blocking symptomatic infection, which was previously required for COVID-19 vaccines.  FDA advisory panel meetings on vaccines for young kids are currently scheduled for June 2022.

Administration Officials Still Tight-Lipped on End of PHE

The Biden administration on Tuesday sent a letter to state governors to urge them to make preparations for the end of the COVID-19 public health emergency (PHE).  However, the administration declined to give any indication as to when it will let the PHE expire, although the letter did reiterate the administration’s commitment to provide states 60 days’ notice before pulling the plug on the PHE.  The PHE is currently set to end of July 16, which means the administration would have to communicate that it will let the current PHE end no later than Tuesday, May 17.  Numerous policies tied to the PHE are immensely important to the states, including Medicaid redetermination and telehealth waivers. 

Reed Officially Resigns from Congress, Takes Job with Lobbying Firm

Rep. Tom Reed (R-NY) officially resigned from Congress on Tuesday, and he will soon start a new role at Prime Policy Group, a government relations firm.  Reed announced in 2021 that he would not seek an additional term following allegations of sexual misconduct.  In a final floor speech, Reed decried “the current focus on extremism” in politics, and he called for “petty political posturing to end.”  Reed was the top Republican on the Social Security Subcommittee of the powerful House Ways and Means Committee, and Rep. David Schweikert (R-AZ) is likely to replace Reed as the subcommittee’s top Republican.  Reed’s resignation will trigger two special elections this year to determine who will succeed Reed in representing New York’s Southern Tier region in Congress.

ICYMI: Paris Hilton Returns to Washington

This week, media personality and businesswoman Paris Hilton was spotted on Capitol Hill and in the White House, where she advocated for legislation to improve the oversight of youth treatment facilities.  Hilton endured psychological abuse at one such facility as a child, and in October 2021, she shared her experiences while testifying before a Utah State Senate panel.  In April, Hilton’s media company began working with a lobbying firm to advance legislation to regulate congregate care facilities for teens.

Tracking CMMI’s Shift to Health Equity

Health equity is the latest focus of the Center for Medicare and Medicaid Innovation (CMMI), which was launched a decade ago to develop and test health care payment models with the goal of saving money for Medicare.  This push for health equity goes back to the very beginning of the Biden administration when he first issued an executive order (EO) on advancing health equity in January 2021.  What steps has CMMI taken to push for health equity since then, and how will CMMI pull it off?

CMMI’s shift to health equity kicked off in October 2021, when the center released a white paper announcing a “strategic refresh” that would judge the success of its models not just on whether they save money but also whether they improve health equity.  Of note, the white paper found that only six models of the more than 50 models CMMI currently has generated substantial savings for Medicare.

CMMI followed-up this strategic refresh in February 2022 when it launched the Accountable Care Organization (ACO) Realizing Equity, Access, and Community Health (REACH) Model, a redesign of the Global and Professional Direct Contracting (GPDC) Model.  A key feature of the ACO REACH model is a requirement for model participants to develop a health equity plan that identifies underserved communities and outlines initiatives to reduce health disparities within their beneficiary populations. 

The ACO REACH Model won’t be the last CMMI model to make health equity a cornerstone.  In March 2022, CMMI Director Liz Fowler said creating a health equity plan will  likely be a requirement for future innovation center models.

CMMI took another bold step on health equity in March 2022 when Chief Medical Officer Dora Lynn Hughes announced in a Health Affairs blog post that the innovation center has added “Advancing Health Equity” as one its five strategic objectives.  In the blog post, Hughes outlines ways CMMI intends to achieve this new objective:

  • Developing new models and updating existing models to promote and incentivize health equity, as demonstrated by the ACO REACH Model.
  • Increasing the participation of safety net providers to ensure models reach underserved communities.
  • Increasing collection and analysis of equity data, primarily by coordinating with other offices in the Department of Health and Human Services (HHS).
  • Monitoring and evaluating models for health equity impact by analyzing beneficiary experience and equity assessments.

Can CMMI pull off its health equity goals?  After all, only a fraction of the center’s 50 models achieved the goal of saving Medicare money, which makes the center’s capability to tack on and carry out another goal seem overly ambitious.

Fortunately, CMMI has a plan.  In her blog post, Hughes stated that the center will have to collaborate with offices and agencies across HHS, particularly those focused on social determinants of health like food, housing, and transportation.  Outside of the government, Hughes said CMMI is already meeting with groups that have not previously engaged with the center, like community-based organizations and patient advocacy groups, and that CMMI is hosting roundtable discussions on health equity to help inform its work. 

On top of this, the Centers for Medicare and Medicaid Services (CMS) is working hard to advance health care interoperability, which CMS Administrator Chiquita Brooks-LaSure said in March 2022 is essential to addressing the “inequities in our health care system.”  Better data collection is one of the four ways CMMI hopes it will achieve its health equity goal, and Brooks-La Sure recently announced that CMS will soon publish a rule on health data exchange.  While CMMI’s success at creating models that reduce Medicare costs may be limited at best, the center has laid out some specific actions it hopes to take to achieve its new goal, increasing the odds this goal can become reality.    

What Happened, What You Missed: January 10-14

CMS Issues Narrow Coverage Determination for New Alzheimer’s Drug

On January 11, the Centers for Medicare and Medicaid Services (CMS) proposed a national coverage determination for Alzheimer’s disease medication Aduhelm that will limit Medicare coverage to patients participating in relevant clinical trials.  The Food and Drug Administration (FDA) approved the Biogen-developed drug last year, despite conflicting data regarding the drug’s efficacy.  Aduhelm attracted significant controversy after Biogen announced a launch price of $56,000, which was later halved due to public outcry.  CMS is holding a 30-day public comment period and will announce its final decision by April 11.

Supreme Court Blocks Vaccine Mandate for Employers, but Not Health Care Providers

On Thursday, the Supreme Court struck down the Occupational Safety and Health Administration (OSHA) mandate for private sector employers to require workers to be vaccinated or regularly tested, on the basis that OSHA lacks the authority to “regulate public health more broadly.”  The high court’s vote to invalidate the vaccine mandate was 6-3, along ideological lines.  However, the Supreme Court did vote to uphold a CMS regulation that requires health care provider that receive money from the federal government to mandate that employees be vaccinated.  According to the majority opinion, CMS was justified to mandate vaccinations because unlike OHSA, the agency has long-standing authority to issue health care mandates.

Sinema Doubles Down on Opposition to Filibuster Reform

Sen. Kyrsten Sinema (D-AZ) strongly expressed her opposition to changing filibuster rules to pass a voting rights bill in an impassioned speech she delivered on the Senate floor yesterday.  While Sinema said she supports the Democrats’ voting rights legislation, she’d prefer to see it advance through more collaboration between Democrats and Republicans.  Sinema’s speech came just before President Joe Biden met with Senate Democrats on Capitol Hill in order to stir up support for voting rights reform.  Both Sinema and her West Virginia Democratic colleague Sen. Joe Manchin’s continued opposition to creating a filibuster carve out for the voting rights bill means Democrats’ hopes of passing the measure are facing an uphill battle and may not get done.   

Johnson Announces Reelection Bid, Perlmutter Announces Retirement

In a Wall Street Journal op-ed, Sen. Ron Johnson (R-WI) announced on January 8 his plans to run for a third term in the Senate, putting an end to months of speculation regarding his plans.  Johnson initially pledged in 2016 to not seek reelection in 2022; however, encouragement from constituents and the nation’s “unsustainable path” caused him to reconsider.  The Senate race in Wisconsin is expected to be close, as President Biden narrowly won the state in 2020.  Later in the week, Rep. Ed Perlmutter (D-CO) announced that he will not be seeking reelection in November.  Representing the north and west suburbs of Denver, Perlmutter served in the Colorado Senate for eight years before his election to Congress in 2006.  In a statement, Perlmutter said he is stepping aside to “explore other opportunities,” but did not specify what those would be. 

ICYMI: Harry Reid Lies In State at US Capitol Building

On Wednesday, former Senate Majority Leader Harry Reid (D-NV) lied in state in the Rotunda at the US Capitol, where President Joe Biden, Vice President Kamala Harris, and dozens of other elected officials paid tribute.   Reid, who worked as a Capitol Police officer while studying law at George Washington University, served for years in the Nevada state government before being elected to the House in 1982 and the Senate in 1986.  Reid’s 30-year Senate career included a decade as Majority Leader, during which he led the Democratic caucus in voting to end the filibuster for most presidential nominations, including federal judges.  Reid retired in 2017 but continued to stay active in the public eye despite his diagnosis of pancreatic cancer in 2018.

What’s Changed for Open Enrollment 2022?

Open enrollment for 2022 kicked off on November 1, and it’s particularly consequential to President Joe Biden, who campaigned on building off the success of the Affordable Care Act (ACA) to expand access to health care coverage.  To deliver on these promises, open enrollment has undergone several key changes to make it more consumer-friendly for 2022. 

  • First off, open enrollment is a month longer than the previous four years.  While open enrollment last year ended on December 15, 2021, for the upcoming plan year, it ends on January 15, 2022.
  • Plan enrollees can also expect record-low prices, thanks to an extension of ACA premium tax credits made possible by the American Rescue Plan.  According to the Biden administration, four out of five people can now find a plan for $10 or less per month.
  • Additionally, 2022 sees a major boost to enrollment assistance.  Plan enrollees for 2022 can now look forward to over 5,000 enrollment assisters and navigators, plus nearly 50,000 brokers and agents.  Notably, the Centers for Medicare and Medicaid Services relaunched a program that engages with local organizations to provide outreach and education.
  • The current open enrollment has a new focus on health equity.  The administration is rolling out new efforts to people who previously lacked access to coverage, and advertising is being conducted in several new languages: Chinese (Mandarin and Cantonese), Korean, Vietnamese, Tagalog, and Hindi.
  • Finally, more Americans than ever will be eligible for open enrollment 2022.  That’s because three states (Kentucky, Maine, and New Mexico) transitioned from state-run coverage to the federal exchange for 2022, bringing the total number of state-based marketplaces on healthcare.gov to 18. 

What Do These Changes Mean for Enrollment?

For plan year 2021, enrollment reached a record high of 12.2 million people, which can be attributed to a special COVID-19 enrollment period that ended in most states in August 2021.  However, many Americans seem to be unaware of premium tax credits made possible by the American Rescue Plan.  According to an October 2021 poll by the Kaiser Family Foundation (KFF), only about a quarter of adults who are uninsured or buy their own insurance checked to see if there were eligible for ACA premium tax credits. 

KFF currently estimates that nearly 11 million Americans are eligible for but not enrolled in subsidized ACA plans.  Despite a record number of enrollees in 2021, it remains to be seen if new outreach efforts, longer enrollment periods, and other changes brought into play for 2022 will be enough to attract more enrollees and continue to lower the number of uninsured individuals in America.

Where Are We at with Medicare’s Temporary Telehealth Waivers?

Telehealth usage has exploded during the COVID-19 pandemic, thanks to legislation like the CARES Act that expanded Medicare coverage of telehealth services to make it easier for beneficiaries to access health care services while minimizing their exposure to COVID-19.  Now that the final stage of the pandemic is (hopefully) winding down, what are the implications for telehealth? 

It’s all about the PHE.  Expanded telehealth coverage is set to expire at the end of the COVID-19 public health emergency (PHE), which is currently January 16, 2021.  The Secretary of the Health and Human Services (HHS) has the authority to renew the PHE for 90-day increments, meaning the PHE could potentially extend through April 2022 – or longer.  Below are key Medicare telehealth coverage restrictions and rules that have been waived for the duration of the PHE.

  • Qualifying Technology: Medicare may now cover telehealth services conducted through devices like smartphones that offer audio-visual capabilities and can be used to facilitate two-way, real-time communication between a beneficiary and a practitioner.  Previously, this was limited to beneficiaries in rural areas.  Additionally, the requirement for visual capabilities is now waived for certain services, meaning some beneficiaries can now use audio-only telehealth services.
  • Geographic Location: Medicare will reimburse for telehealth services anywhere in the US, with no pre-existing patient relationship required.
  • Qualifying Service: Medicare can reimburse 238 telehealth services, compared to 101 prior to the PHE. 
  • Qualifying Originating Site Type: Telehealth services can be provided to all patients in all settings, including at a beneficiary’s home.
  • Qualifying Site Practitioner: Any health care practitioner who can bill Medicare may now furnish Medicare telehealth service.

All of these temporary changes expire once the PHE ends, but Congress could take action and can change that. Lawmakers from both parties have been pushing to take some of these temporary telehealth coverage extensions and make them permanent, beyond the PHE. 

  • Several bills (S. 368, S. 1988, H.R. 341, H.R. 1332, and H.R. 5425) would strike Medicare’s geographic site originating requirement and allow Medicare beneficiaries to access telehealth services in all settings. 
  • Another (H.R. 2168) would permanently allow audiologists, physical therapists, occupational therapists, speech-language pathologists, and other providers to provide telehealth services under Medicare.
  • Additional bills (H.R. 5425 and S. 1988) would ensure permanent Medicare coverage of certain telehealth services using audio-only technology.

However, none of these have bills have advanced in either chamber since their introduction, and the Build Back Better Act, Democrats’ social spending and climate package, does not contain any provisions that address Medicare coverage of telehealth services.

It would be amiss not to highlight a major barrier to continued telehealth coverage is reimbursement.  Under the PHE, telehealth services are reimbursed under Medicare at the same rate as in-person services, and lawmakers and stakeholders disagree over whether permanently expanded telehealth services should be reimbursed at or below the level of in-person services. 

So, what does the future hold for telehealth?  In summer and fall 2020, more than a quarter of Medicare beneficiaries used telehealth services, representing a massive increase in telehealth utilization since before the pandemic.  Given that the waiver of Medicare’s telehealth restrictions will expire once the PHE ends, the question of what telehealth coverage will look like post-pandemic looms large.  The numerous proposals on Capitol Hill to expand certain telehealth flexibilities suggest lawmakers want to ensure beneficiaries have continued access to telehealth services.  However, absent any serious progress on these proposals, Medicare beneficiaries are still staring down the very real possibility of losing popular, safe, and convenient ways to access medical treatment that they gained in the early days of the pandemic.   

After 10 Years, How Is the CMS Innovation Center Doing?

The Center for Medicare and Medicaid Innovation (CMMI), also known as the CMS Innovation Center, just celebrated its tenth birthday last year.  Tasked to address growing concerns about rising costs, quality of care, and inefficient spending, CMMI is a powerful tool for innovation in the US health care system.  After a decade, is CMMI delivering on its promise to innovate health care, or does the young agency still have much to accomplish?

All About CMMI

Created upon enactment of the Affordable Care Act (ACA) in 2010, CMMI is statutorily mandated to design, implement, and test new health care payment and delivery models for Medicare and Medicaid.  Managed by the Centers for Medicare and Medicaid Services (CMS), CMMI has launched over 40 new payment models since its inception, including accountable care organizations, medical homes models, and bundled payment models.  CMMI separately awards grants to state agencies, researchers, and other organizations for projects to design and implement new payment models with the same goals of improving care and lowering costs, and some of CMMI’s work includes multi-payer alignment models that impact patients with commercial insurance. 

2020 Report to Congress

Released on August 4, the 2020 Report to Congress provides an in-depth look at the performance of CMMI models and serves as a key indicator of how the center is doing in its effort to address rising costs and boost quality.  While the report focuses on CMMI’s activities from October 1, 2018, to September 30, 2020, it also highlights some actions taken from September 30 to December 31, 2020. 

In the 2020 Report, CMS estimated that over 27.8 million Medicare and Medicaid beneficiaries plus enrollees in commercial insurance plans have received care from over 500,000 health care providers or plans participating in alternative payment models under CMMI.  The 2020 Report analyzed a total of 38 active models within CMMI, including 11 new models announced since the 2018 Report and 27 active models that were launched prior to October 2018.

Summary of Findings

Unfortunately, only a handful of CMMI models met either goal of reducing costs or improving quality.   Furthermore, only the five following models delivered “statistically significant savings” to the Medicare Trust Fund according to the report:

Additionally, a few models led to improvements in quality but did not yield any noteworthy savings, including the Comprehensive End-Stage Renal Disease (ESRD) Care (CEC) Model and the Comprehensive Care for Joint Replacement (CJR) Model.

Saving money and raising quality aren’t the only metrics for a model’s success.  For CMS to consider permanently expanding a model for the federal health care entitlement programs, models must meet several additional criteria, including assurance from the CMS Office of the Actuary that a model’s expansion would not deny or limit coverage or provision of benefits under Medicare, Medicaid, and CHIP.   According to the report, only three models met the criteria:

How Can CMMI Improve?

While the 2020 Report to Congress does not explicitly offer recommendations on how to improve model performance, it does identify four issues that contributed to lower-than-expected model performance:

  • Selection bias created by voluntary models.
  • Benchmark inaccuracy.
  • Quality measure misalignment.
  • The need for greater data transparency.

These four issues identified in the report suggest a few ways CMMI models could produce better quality and provide for lower costs, mainly through mandatory model participation and more data transparency.  The idea of making more payment models mandatory is not a new idea.  In a July 2021 interview with Health Affairs, CMMI Director Liz Fowler explained that a shift towards mandatory models, which had already begun during the previous administration, will continue under the Biden administration and are likely to play a greater role in CMMI’s future.

The fact that CMMI models are underperforming is not lost on CMS leadership.  In a recent Health Affairs blog post, a few top agency officials including CMS Administrator Chiquita Brooks-LaSure and Fowler acknowledged only a handful of models have incurred savings and met the requirements to be expanded.  In addition to recounting a few recommendations from outside experts, such as MedPAC’s endorsement for streamlining and harmonizing models, Brooks-LaSure and Fowler offered several takeaways to inform how model performance could be improved.

  • CMMI needs to reevaluate how it designs financial incentives in order to boost meaningful provider participation.
  • Challenges in setting financial benchmarks have undermined models’ effectiveness, underscoring a need to ensure models are not resulting in overpayment and explore ways to improve or replace the current risk adjustment methodology. 
  • Since providers find it hard to accept downside risk if they lack the tools to change care delivery, CMMI should help ensure providers have options for managing risk, such as support in transforming care, waivers, and data. 

Despite dozens of underperforming models, CMS recognizes that the Innovation Center has room for improvement, and the agency’s leaders are keen on delivering a strategy that works.  Hopefully, through streamlining current models, implementing more mandatory models, boosting participation in voluntary models, improving financial incentives, and ensuring model participants have the tools they need to succeed, CMMI models could hopefully be in a better position to  both reduce costs and improve quality in time for the center’s 20th anniversary.

What Happened, What You Missed: July 12-16

CMS Proposes to Extend Some Telehealth Services through 2023

In its physician fee schedule for 2022, the Center for Medicare and Medicaid Services (CMS) proposed extending coverage for some Medicare telehealth services through the end of 2023.  Under the rule, CMS is proposing to remove certain statutory restrictions to allow patients in any geographic location and in their homes access to telehealth services for diagnosis, evaluation, and treatment of mental health disorders and allow for coverage of audio-only telehealth services to apply to counseling and therapy for opioid treatment.  The release of the proposed rule comes just one day after a group of bipartisan House Energy and Commerce Committee members sent a letter to Health and Human Services (HHS) Secretary Xavier Becerra urging the Department to make Medicare coverage for some telehealth services added under the public health emergency permanent.  Comments on the proposed rule are due on September 13. 

Senate Democrats Reach Agreement on $3.5 Trillion Infrastructure Package

On July 13, Senate Majority Leader Chuck Schumer (D-NY) announced an agreement on a $3.5 trillion “human infrastructure” package after a meeting with Democrats on the Senate Budget Committee.  Major proposals include subsidized child care, national paid family leave, free community college, a host of climate change initiatives, and expanding Medicare coverage for vision, dental, and hearing services.  Democrats are hoping to pass the legislation through budget reconciliation, which would allow the bill to advance in the evenly split Senate with a simple majority.  However, it remains to be seen if the White House and Democratic leadership can count on all Senate Democrats to support the package, including moderate Democrats like Sen. Joe Manchin (D-VW), who is concerned about how the legislation will be paid for.

Drug Overdose Deaths Hit New Record in 2020

According to data from the Centers for Disease Control and Prevention, drug overdose deaths increased nearly 30% from 2019 to hit a record high of over 93,000 in 2020.  A contributing factor is the widespread use of fentanyl, which can halt breathing even if a small amount is ingested. Additionally, the pandemic played a significant role in the increase of deaths, strained health care resources, and made addiction treatment more difficult to obtain.   

CMS Studying How Much Medicare Should Pay for New Alzheimer’s Drug

On July 12, CMS launched a National Coverage Determination analysis to determine whether and under what circumstances Medicare should cover Biogen’s recently approved Alzheimer’s drug Aduhelm. Aduhelm has attracted controversy for its high price tag of $56,000 and inconsistent efficacy in clinical trials. Furthermore, on July 15, a group assembled by the Institute for Clinical and Economic Review unanimously agreed that Aduhelm does not work better than existing Alzheimer’s treatments. However, CMS will propose a decision within six months and then allow stakeholders to comment within a 30-day period with CMS making a final decision three months later. Until then, Medicare Administrative contractors will be left to make coverage determinations for the Alzheimer’s drug. 

ICMYI: Library of Congress Reopens to the Public

On July 15, the Library of Congress reopened to the public, marking a major step in reopening the US Capitol complex.  Visitors are required to get tickets online for a timed entry on Thursday, Friday, or Saturday, and face masks are required for all visitors regardless of vaccination status.  The library’s Thomas Jefferson building is considered an architectural gem and was modeled after the Pantheon in Rome.  However, it’s unclear when the Capitol itself will reopen to the public. 

CMS Puts Geo Model on Hold

On March 1, the Center for Medicare and Medicaid Services (CMS) announced its Geographic Direct Contracting Model is “currently under review” until further notice.   While CMS has yet to provide a reason for the pause, criticism from industry stakeholders and the new Center for Medicare and Medicaid Innovation (CMM) Director may explain the pause.

Announced in December 2020, the Geographic Direct Contracting Model, or the “Geo Model,” envisions using direct contracting entities (DCEs) to build integrated relationships with health care providers and coordinate care for Medicare beneficiaries in designated geographic regions.  The model, which had been under development for two years, builds on lessons learned from the Next Generation ACO model, Medicare Advantage, and other initiatives.

However, the Geo Model is the only CMMI model that has been paused by the new Administration so far.   In the absence of an official justification from CMS, one of the reasons why the model may have been put on hold was criticism from health care stakeholders.  In a December 2020 letter to then-CMMI Director Brad Smith, the National Association of ACOs warned the model could generate confusion among beneficiaries over who is compelled to participate.  Additionally, the Center for Medicare Advocacy urged the then-Biden Transition Team in a December 2020 letter to halt the Geo Model due to uncertainty over how the model would work with other forms of insurance such as Medigap.

The move to suspend the Geo Model is not entirely without precedent.  The Biden Administration paused or withdrew numerous actions by the previous Administration since assuming power, which is typical for new presidential administrations.  For instance, CMS has withdrawn proposed rules on oversight for accrediting organizations, revisions to dialysis coverage requirements, and changes to Medicare Part A enrollment requirements since January 20. 

It should be noted that not all stakeholders oppose the Geo Model.  In a March 4 letter, America’s Physician Groups urged CMMI to restart the model as soon as possible due to “extensive financial investments” participating providers have already made in preparation for the model’s launch, as well as a genuine belief that the model represents a meaningful shift away from the fee-for-service model.

In addition to external criticism, pressure to put the Geo Model on hold may have come from within CMMI itself.  Recently, the Biden Administration tapped Liz Fowler to serve as CMMI Director.  Prior to her new leadership role at CMS, Fowler served as Executive Vice President for Programs at the Commonwealth Fund, where she co-authored a December 2020 blog post about the Geo Model.  While the blog post largely served as an explainer for the model, it raised several questions, including how CMS would be able to produce savings CMS had projected and whether CMS is adequately tracking beneficiaries’ use of services under the model.

Thus, pressures from both inside and outside CMS have likely led to the Administration’s decision to suspend the model for the time being.  That said, while not knowing yet where CMMI may take the geographic-based care and payment model, it certainly seems possible that the Administration could choose to pause other CMMI models in the future.