November 06, 2018 03:44 pm News Staff – Family physicians must have the flexibility to collaborate with other physicians and health care professionals to provide team-based, patient-centered care that incorporates new technologies and focuses on reducing the total cost of care.
Not so obvious that the Academy didn't spell out that imperative -- verbatim -- to HHS' Office of Inspector General (OIG) in a recent letter.
The call for flexibility was part of the AAFP's response to a request for information (RFI) titled "Medicare and State Health Care Programs: Fraud and Abuse" that was published in the Aug. 27, 2018, Federal Register.
The Oct. 25 letter, which was signed by AAFP Board Chair Michael Munger, M.D., of Overland Park, Kan., urged that HHS commit to, and invest in, physician-led advanced alternative payment models (AAPMs). Such practices, the AAFP advised, "effectively strengthen the long-term solvency of the Medicare program and deliver patient-centered care to beneficiaries."
The letter bolstered the Academy's August message to CMS about self-referral law and its impact on innovation -- including that represented by the AAFP's Advanced Primary Care Alternative Payment Model. In both communications, the AAFP recommended that CMS produce a simple decision tree for medical practices seeking to innovate or collaborate without drawing undue scrutiny.
"We urge the OIG to offer timely, broad and clear flexibility for AAPMs and for prompt and clear guidance on safe harbors," the letter said.
Addressing other elements of the RFI, the Academy recommended that
In its discussion of risk, the letter further noted that the AAFP "opposes putting primary care practices and their eligible clinicians at risk for anything beyond their own performance under a model."
Warning that not every primary care practice is equipped to accept the same level of risk at the same time, the letter added: "That particularly extends to insurance risk and utilization of services outside the control of the practice (e.g., total cost of care). Assumption of risk for total cost of care may also reduce participation in a model -- especially among small or independent practices."
Overall, the letter noted, "We urge the OIG to confirm that any action from CMS will allow for physician collaboration/new partnerships that improve care delivery and appropriate beneficiary incentives."
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