Mr. Sean Cavanaugh
Deputy Administrator and Director
Department of Health and Human Services
Attention: CMS-5517-P P.O. Box 8013
Baltimore, MD 21244-8013
June 20, 2016
Dear Mr. Cavanaugh:
Thank you for the opportunity to review and provide comments to the Centers for Medicare & Medicaid Services (CMS) on the Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models [CMS-5517-P].
MedNetOne Health Solutions is appealing to CMS to recognize robust regional programs like Blue Cross Blue Shield of Michigan’s (BCBSM) Patient Centered Medical Home (PCMH) designation program when assigning credit in the MIPS Clinical Practice Improvement Activities (CPIA) category. MedNetOne is a healthcare management organization firmly rooted in primary care. Its Practice Transformation Coaches and Quality Improvement Team work closely with small to medium size primary care practices to guide them through the steps of obtaining Patient-Centered Medical Home designation and providing patient-centered care team-based care. This is a daunting task which often requires infrastructure support and ongoing QI coaching.
I would like to call to your attention that the BCBSM PCMH designation program is the largest independent program of its kind in the country with over 4,500 PCMH-designated PCPs in more than 1,600 practices and that PCMH designated practices are found in 80 of Michigan’s 83 counties. It was developed in partnership with different physician organizations throughout Michigan, is updated annually based on feedback from participating clinicians and has been endorsed by both the Michigan Osteopathic Association and the Michigan State Medical Society. The BCBSM designation process aligns closely with other national certification standards, with emphasis on population health management using advanced all-payer patient registries, team-based care management and self-management support. It also requires no application fee for practices seeking PCMH designation, which can be cost-prohibitive for smaller practices and thereby discouraging the PCMH journey.
MedNetOne primary care clinicians support the tenets of the PCMH model. In my own BCBSM PCMH designated practice I have not only a patient registry specialist but a full multidisciplinary team providing patients onsite access to a behavioral health specialist, a dietitian, a health coach and health educator. This team would not be in my practice and in hundreds others throughout Michigan had the BCBSM PCMH program not provided instructions and support to build a solid “home” for patients.
We hope CMS will consider our feedback and recognize existing PCMH programs and partnerships between local payers and clinicians when it finalizes the MIPS and APM rule.
Al Juocys, D.O.
Chief Medical Officer
MedNetOne Health Solutions