CMS Response to NTH

Over a year ago, nursestransforminghealthcare.org (NTH) reached out to CMS

OK, let’s see what CMS said in response to our outreach to them:

“CMS shares your desire and commitment to ensuring that communities across the country have equitable access to high-quality, integrated, person-centered care.”

Good rhetoric, but they have no plan to achieve this

“Health care relationships that address beneficiaries’ comprehensive needs—including medical, behavioral, and social needs - will be fundamental to lasting health care transformation, especially among historically marginalized populations.”

Again, good rhetorical goal but without a plan to get there.

“The Accountable Health Communities (AHC) Model is one such example of the CMS Innovation Center’s work to empower local practitioners and incentivize coordination across community partners. Specifically, the AHC Model seeks to address a critical gap between clinical care and community services by systematically identifying and addressing the health-related social needs of Medicare and Medicaid beneficiaries’ through screening, referral, and community navigation services.”

Once again, the focus is trying to put a round peg in a square hole. Funneling any kind of delivery process through the lens of insurance systems is fruitless, and as long as the “systems” focus is on profits, these services are going to require either financial support from taxation or massive throughput for any kind of consistent community presence.

“Additionally, I appreciate that your proposed PUM structure emphasizes the importance of fostering trust within the doctor-patient relationship.”

That is not what this system does, it helps establish trust between the state based regional systems, providers and the community by providing a stable presence IN the community. We are NOT talking value-based-care, that’s a meaningless term. We are talking having providers of every specialty able to provide services to the scope of their licenses, many as independent practitioners, based on the identified needs of the communities.

“With this in mind, CMS has set aggressive goals for patient-provider relationships over the next 10 years: CMS aims to have all Medicare beneficiaries with Parts A and B, as well as a majority of Medicaid beneficiaries, in a care relationship with accountability for quality and total cost of care by 2030.”

Our goal is to remove the need for Medicare and Medicaid, and all insurance for that matter, by refocusing healthcare as a service provided to the community and not based on individual billable interactions. Having an “aggressive” 10 year goal is again kicking the can down the road as we have been over the past 50 years with the exception of the PPACA. As it is, CMS users frequently have to buy additional insurance such as Medicare Advantage.

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?“Beyond reducing costs and improving quality, a successful strategy will also be measured by how the Innovation Center’s models impact CMS programs, patients, families, providers, payers, and the broader health care system to ensure all benefit from and participate in the new vision.”

CMS has been around since the 1960’s. Where has your “innovation” been? The system, as it is, is dysfunctional to a vast number of Americans and our Public Health has deteriorated to a point of absurdity. Not to mention that the political party’s have turned healthcare into a political football with the potential for seeing the entire PPACA stripped away, or at best, only incremental changes as fortunes provide.

“To this end, CMS will offer more consistent communication and opportunities for collaboration among partners at the national, regional, state and local level. I would encourage you to sign up for our listserv as CMS will have a number of listening sessions and other opportunities for stakeholder engagement in the near future.”

CMS is just joining the ranks of the hackers, innovators, and disrupters who are focused on the process level and expecting these efforts to lead to real systemic reform without addressing the elephant-in-the- room, the system design, which is determining the processes to begin with. What partners are you expecting? Who are your unidentified stakeholders?

“CMS hopes that by launching fewer models that are more harmonized and by rethinking how CMS defines success and model outcomes, CMS can zero-in on what works and appropriately scale best practices to effect lasting change for the U.S. health system.”

First, there is no US health system, only a disparate group of profit centers who happen to provide resources for illness care. What does launching fewer models even mean? BY what standards will CMS decide what works and just how can CMS scale best practices in this environment?

CMS can’t even control the rampant fraud in this non-system.

I appreciate this response from CMS, but we’re not waiting 5 years or 10 years to begin the process of true structural reform. There are critical needs out there right now and the PUM model has proven results.

In so far as CMS is willing to listen and participate in a genuine discussion about meaningful reform, NTH (nursestransforminghealthcare.org) is more than willing to participate. If the only goal is to incrementally inch our way to a hopeful outcome 10 or 20 years from now, we are not and will pursue our own course.

Come join us as we try to effect REAL change