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.