Application to Use Burden/Hours from Generic PRA Clearance:
Health Care Payment Learning and Action Network
(CMS-10620, OMB 0938-1297)
Generic Information Collection (GenIC):
Tracking the adoption of alternative payment models
Office of Communications (OC)
Centers for Medicare & Medicaid Services (CMS)
Changing the way health care is paid for in the United States is a key priority for health reform. Medical treatment and services have traditionally been paid for in a fee-for-service manner, rewarding clinicians for the quantity of care they provided. Alternative payment models (APMs) are designed to reward providers for the quality, efficiency, and coordination of their care. All APMs and payment reforms that seek to deliver better care at lower cost share a common pathway for success: providers, payers, and others in the health care system must make fundamental changes in their day-to-day operations that improve quality and reduce the cost of health care. Making operational changes will be viable and attractive only if new alternative payment models and payment reforms are broadly adopted by a critical mass of payers. When providers encounter new payment strategies for one payer but not others, the incentives to change are weak. When payers align their efforts, the incentives to change are stronger and the obstacles to change are reduced. As a result, the U.S. health care system will shift from a fee-for-service predominant system to one in which most care is provided through APMs.
The Health Care Payment Learning and Action Network (LAN) has brought together private payers, providers, employers, state partners, consumer groups, individual consumers, and many others to accelerate the transition to APMs. In early March 2016, the U.S. Department of Health and Human Services (HHS) announced that an estimated 30% of Medicare fee-for-service payments are now tied to APMs, thus reaching the first HHS milestone almost a year ahead of schedule.
To assess the adoption of APMs across the U.S. health care system, in 2016, the LAN launched a measurement effort focused on the adoption of APMs in the commercial sector, Medicare Advantage, and state Medicaid programs. The LAN structured its measurement efforts based on the work of the multi-stakeholder Alternative Payment Model Framework & Progress Tracking (APM FPT) Work Group, which had developed an APM Framework for categorizing APMs. In early 2016, nine participants from the LAN Payer Collaborative, a group of over 20 health plans and associations, volunteered to participate in a pilot of the survey instrument. The results of the pilot played an integral role in informing the data collection protocol and provided the LAN the opportunity to improve and maintain best practices moving toward a national effort.
Following the pilot, the LAN employed a multifaceted strategy (March-May 2016) to recruit health plans, and eventually Medicaid FFS states, to participate in a national effort to help gauge progress on the pathway to payment reform. In total, 70 leading health plans (over 100 plans including affiliates) and 2 states participated in an 8-week quantitative data survey from May 19 to July 13. Individual plan data, kept confidential, was aggregated into a composite number that serves as an indicator of APM adoption. These aggregated results were presented at the fall LAN Summit on October 25, 2016 and can be found here on the LAN website. The LAN repeated this strategy in 2017, managing to collect data from over 80 participants, accounting for nearly 245.4 million Americans, or 84%, of the covered U.S. population. This report was presented at the October 2017 LAN Summit and shows progress, with 29% of total U.S. health care payments tied to alternative payment models (APMs) in 2016 compared to 23% in 2015, a 6 percentage point increase.
In 2018, the LAN once again carried out a measurement effort, this time adding five simple informational questions about the current and future state of payment reform from the payer’s perspective. The LAN surveys participants to understand LAN participant opinions, priorities, and issues with respect to how to best increase the adoption of alternative payment models. These additional five questions will inform decision making about future LAN activities, including LAN Conference sessions, webinar topics, and feedback on LAN work group ideas. The LAN shared the 2018 results at the LAN Summit, finding that 34% of total U.S. health care payments were tied to alternative payment models (APMs) in 2017 compared to 29% in 2016, a 5 percentage point increase. The LAN reported the 2018 results by line of business at the subcategory level using the definitions and categories provided in the Refreshed Framework.
Though the LAN survey is one of the largest and most comprehensive efforts to measure adoption of APMs conducted to date, there is still more work to be done. The LAN’s proposed 2019 data collection initiative will build upon the 2016 baseline and 2017, 2018 progress and will help CMS further understand differences in APM adoption among commercial, Medicaid, Medicare Advantage, and FFS Medicare business.
B. Description of Information Collection
The purpose of this information request is to repeat, for purposes of measurement and comparison, the 2016, 2017, 2018 data collection efforts by collecting health care spending data from commercial, Medicaid, Medicare Fee-For-Service and Medicare Advantage payers to track the health system’s progress in adopting APMs. The goal is a consistent and harmonized “apples-to-apples” comparison of the various payment models in use nationwide.
The current, refreshed APM Framework, which expanded and refined the original APM Framework, classifies payment models into four categories:
Category 1—fee-for-service with no link of payment to quality;
Category 2—fee-for-service with a link of payment to quality;
Category 3—alternative payment models built on fee-for-service architecture; and
Category 4—population-based payment.
Using a similar protocol from the 2016, 2017, and 2018 collection efforts, health plans will be asked to provide their spending in each of the APM Framework categories, as well as their total in- and out-of-network spend and total in-network spend, for CY 2018 or the most recent 12 months over all lines of business. Similar to the 2018 effort, the 2019 measurement effort will also ask five simple informational questions about the current and future state of payment reform. These questions are straightforward opinion-based questions from the payer’s perspective. (See informational questions attachment for more information and the APM data collection tool to review each of the five questions.)
Recruitment efforts for the 2019 LAN APM Measurement Effort will be similar to 2018. In 2019, the LAN will again partner with America’s Health Insurance Plans (AHIP) and the Blue Cross Blue Shield Association (BCBSA) and support participation of their member plans in the associations’ APM survey. Similar to 2018, both BCBSA and AHIP will voluntarily collect the same APM data the LAN is collecting, to capture payments by line of business. Unlike the 2018 effort where some AHIP plans responded directly to the LAN survey, in 2019, AHIP plans will report exclusively to AHIP and AHIP will then provide aggregated data to the LAN for inclusion in the final analysis. Thus, we have decreased our burden estimate to reflect a decreased number of plans reporting directly to the LAN. The LAN plans to recruit 50 health plans in 2019 to submit data directly to the LAN. The LAN will receive aggregated data from AHIP and BCBSA, with no access to individual member plan responses.
BCBSA will field its own survey for its own purposes in alignment with the LAN’s APM methodology, and similar to AHIP, the LAN will only receive aggregated BCBSA data with no access to individual BCBSA member health plan responses.
Recruitment and notice for the 2019 data collection begins in April 2019, beginning with 2018 participants. As part of this recruitment effort, the LAN will launch a 2019 Progress Measurement website. The LAN will advertise this website and the measurement effort through a variety of communication mediums, such as LAN newsletters, blogs, and at the LAN events.
The 2019 APM measurement website will be designed to support participants in the 2019 LAN APM measurement effort. It will include:
2019 APM National APM Metric Overview (attached)
Information on the 2019 APM Data Collection tool
A 508-Compliant pdf version of the data collection tool will also be available
An Excel version of the 2019 metrics is attached for reference
Frequently Asked Questions (FAQ) (attached)
Link to the original and refreshed APM Framework white papers
Note that this 2019 APM measurement website is still under development, and will be accessible through the following link: 2019 APM Progress Measurement website. Document versions of the metric overview, FAQs, and survey tools are also attached to this request.
No deviations are requested.
Payer burden was collected for the 2016 and 2017 with an average of 23 hours per health plan. Following the LAN’s burden estimate, the additional informational questions only raised the total payer burden hours by 2 hours, meaning the total payer burden hours reported by participating in 2018 was 25 hours. Additionally, a significant number of participants will be able to leverage the analyses established in 2016, 2017, and 2018. For these reasons, the burden for 2019 should not exceed 25 hours per health plan.
For the fourth consecutive year, the LAN is partnering with AHIP and BCBSA who are fielding their own surveys for their own purposes in alignment with the LAN. In 2019, the LAN will receive aggregated data from AHIP and BCBSA, with no access to individual member plan responses. In addition to plans participating through AHIP and BCBSA, the LAN will directly recruit up to 50 commercial plans and Medicaid FFS states to participate directly. In order to yield a meaningful representation of the U.S. health care market, the survey aims to represent greater than 60% of covered lives, with the objective to build upon the 77% representation achieved in the 2018 survey.
Data will be collected via a Qualtrics collection tool that will be sent directly to participating payers. No incentives will be offered. The total approved burden ceiling of the generic ICR is 25,917 hours. We are requesting a total deduction of 1,250 hours from the approved burden ceiling (maximum 50 participants x 25 hours = 1,250 hours).
The data collection effort is scheduled to run from May 15 - July 30, 2019. The results of the survey will be publicly reported at the LAN Summit to be held in October 2019.
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