The Center for Medicare and Medicaid Innovation (CMMI) is a government body established by the Affordable Care Act (ACA) to test new models for paying for and delivering health care. The ACA gives CMMI significant flexibility and broad authority to try a wide range of new payment and delivery models. These can include “alternative payment models,” such as accountable care organizations, bundled payments and patient centered medical homes or more direct changes to Medicare coverage and payment.
CMMI works differently than other government agencies. It is not required to follow a formal rulemaking process or provide opportunities for public comment.
CMMI’s broad testing authority results in unchecked ability for the agency to make rapid, broad and unpredictable changes to payment policy. These challenges came to light most recently when CMMI announced proposals for several mandatory payment demonstrations, including the mandatory joint replacement model, the mandatory cardiac demonstration and the Part B drug payment model. All illustrate the consequences for patients, providers and stakeholders. CMMI safeguards are needed so new payment models can be tested and pursued, while protecting quality and patient access to needed care.