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Association Submits Response to Innovation Center New Direction

In a November 17 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals responded to a Request for Information (RFI) on the CMS Innovation Center’s new direction.

CMS announced in September that the agency was soliciting comment on a new direction for the Innovation Center, focused on patient-centered care and market-based reforms. The RFI specified eight focus areas in which it would like to test new models.

In the letter, America’s Essential Hospitals urged the Innovation Center to:

  • consider models that allow for operational flexibility to ensure access;
  • ensure flexibility for voluntary participation in Advanced Alternative Payment Models;
  • pursue changes to reduce regulatory burden in health information technology;
  • provide information to the public in a clear, concise manner;
  • consider models focused on hospitals treating high numbers of complex patients;
  • encourage innovation at the state and local levels through the use of Section 1115 demonstrations;
  • look into existing models to further integrate behavioral health and primary care services;
  • focus prescription drug models on reducing Part D drug expenditures;
  • ensure that new models in Medicare Advantage adequately reimburse providers that take on complex cases;
  • allow for waivers of Medicare requirements that impede care coordination; and
  • identify models that allow for additional flexibility in the use of telehealth services.

Contact Director of Policy Erin O’Malley at or 202.585.0127 with additional questions.


About the Author

Rachel Schwartz is a former policy associate at America's Essential Hospitals.

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