Commenting yesterday on the Geographic Population-Based Payment model option of the Primary Cares Initiative, AHA urged the Centers for Medicare & Medicaid Services “to develop the model as transparently as possible so that potential applicants can make fully-informed decisions about applying for participation.” Responding to the agency’s request for information on the proposal, AHA said the RFI for the direct contracting model raises important questions about the model’s parameters and implementation, but “the lack of detail makes it difficult for providers to conduct well-informed analyses in response to the questions.” Among specific comments, AHA urged CMS to ensure that the PBP amount “is sufficient to provide participants with adequate resources to address both the medical and non-medical needs of community members,” and to apply a “robust” risk-adjustment methodology when setting benchmarks for participants. The letter also asks CMS to waive self-referral and anti-kickback regulations relevant to financial arrangements formed by participating providers, as well as antitrust barriers to participants entering into financial arrangements necessary to succeed under the model. 
 

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