Supporting Statement for Paperwork Reduction Act Submissions – Part A
Generic Clearance for the Health Care Payment Learning and Action Network
(CMS-10575, OMB 0938-1297)
The purpose of this submission is to request an extension for our current Generic Clearance for the Health Care Payment Learning and Action Network (CMS-10575).
Background
The Center for Medicare and Medicaid Services (CMS), through the Center for Medicare and Medicaid Innovation, develops and tests innovative new payment and service delivery models in accordance with the requirements of section 1115A and in consideration of the opportunities and factors set forth in section 1115A(b)(2) of the Act. To date, CMS has built a portfolio of models (in operation or recently announced) that have attracted participation from a broad array of health care providers, states, payers, and other stakeholders. During the development of models, CMS builds on ideas received from stakeholders—consulting with clinical and analytical experts, as well as with representatives of relevant federal and state agencies.
CMS will continue to partner with stakeholders across the health care system to catalyze transformation with alternative payment models. To this end, CMS launched the Health Care Payment Learning and Action Network, an effort to accelerate the transition to alternative payment models, identify best practices in their implementation, collaborate with payers, providers, consumers, purchasers, and other stakeholders, and monitor the adoption of value-based alternative payment models across the health care system. A system wide transition to alternative payment models will strengthen the ability of CMS to implement existing models and design new models that improve quality and decrease costs for CMS beneficiaries.
Justification
The CMS Innovation Center was established by section 1115A of the Social Security Act (as added by section 3021 of the Affordable Care Act). Congress created the CMS Innovation Center to test “innovative payment and service delivery models to reduce program expenditures… while preserving or enhancing the quality of care” provided to those individuals who receive Medicare, Medicaid, or Children’s Health Insurance Program (CHIP) benefits. The CMS Innovation Center’s mandate gives it flexibility within the parameters of section 1115A(b)(2) to select and test the most promising innovative payment and service delivery models. Under section 1115A(a)(3), the CMS Innovation Center is also directed “to consult representatives of relevant Federal agencies, and clinical and analytical experts with expertise in medicine and health care management” and to “use open door forums or other mechanisms to seek input from interested parties” when carrying out 1115A activities.
To more effectively partner with stakeholders across the health care system and accelerate system transformation, CMS launched the Health Care Payment Learning and Action Network (LAN) to accelerate the transition to Medicare and non-Medicare alternative payment models by collaborating with a broad array of health care delivery stakeholders, identifying best practices in their implementation, and monitoring the adoption of value-based alternative payment models across the U.S. health care system—to include the percentage of Medicare, Medicaid, and nonMedicare payments tied to (and U.S. lives covered by) alternative payment models that reward the quality of care delivered.
CMS requests an extension for its current generic clearance to continue assisting in monitoring and characterizing the adoption of alternative payment models in order to meaningfully inform 1115A model decisions on the design, selection, testing, modification, and expansion of innovative payment and service delivery models in accordance with the requirements of section 1115A, which would in turn contribute to progress toward the HHS and CMS goals to increase the percentage of payments tied to alternative payment models and the number of people in a care relationship with accountability for quality and total cost of care. To this end, CMS, through its LAN support contractor, may use the requested extended generic to make four types of information requests to stakeholders:
Requests for self-reported identification information from participants when signing up for the LAN and associated events (LAN Summits, webinars, and other meetings) to understand the types of stakeholders participating in LAN activities (providers, payers, consumers, states, etc.).
LAN participant surveys to understand participant opinions, priorities, and issues with respect to how to best increase the adoption of alternative payment models. Surveys will inform decision making about future LAN activities, including LAN Conference sessions, webinar topics, and feedback on LAN work group ideas.
Information requests to LAN payers to track the adoption of alternative payment models among LAN participants. Requested information for each respondent may also include estimated counts and percentages of US beneficiaries/consumers who are covered by alternative payment models, to include underserved populations, and the percentage of payments made through alternative payment models. This information will help the LAN understand general market trends and the pace of progress toward alternative payment model adoption across public and private payers.
Information requests intended to track other characteristics of alternative payment model adoption among certain LAN participant types—employers, providers, states, and so on. This information will help the LAN understand how other stakeholders are contributing to market trends and the pace of progress toward alternative payment model adoption across the U.S. healthcare system. An example could be an information request on employer practices around purchasing health care for employees, to include the types of payment models used.
The information collected from LAN participants will be used by the CMS Innovation Center to potentially inform the design, selection, testing, modification, and expansion of innovative payment and service delivery models in accordance with the requirements of section 1115A, while monitoring the percentage of payments tied to alternative payment models across the U.S. health care system. In addition, the requested information will be made publically available so that LAN participants (patients, providers, payers, consumers, employers, and state agencies) can use the information to inform decision making and better understand market dynamics in relation to alternative payment models.
The forms for collecting this information from LAN participants will be available in electronic format, and we expect every submittal to be completed using the electronic format. The forms create streamlined and structured data, decreasing the time required by LAN participants to develop their submissions to CMS via the LAN’s contractor.
This information collection does not duplicate any other effort and the information cannot be obtained from any other source. Similar efforts in the U.S. health care system to monitor value-based payments will be leveraged as appropriate.
We expect the impact on small businesses who are LAN participants to be minimal. We also plan to engage small businesses in the survey design phases to ensure the questions being asked are well structured and minimize burden.
Absent the ability to collect the four types of information from LAN participants, CMS will not be able adequately track the adoption of alternative payment models across the U.S. health care system, to include using this information to meaningfully inform 1115A model decisions on the design, selection, testing, modification, and expansion of innovative payment and service delivery models in accordance with the requirements of section 1115A.
We do not expect these requests for information from LAN participants to require special circumstances.
Federal Register/Outside Consultation
The 60-day Federal Register notice published to the Federal Register 12/06/2021 (86 FR 69059).
No comments were received
The 30-day Federal Register notice published to the Federal Register 2/22/2022 (87 FR 9625).
Payments/Gifts to Respondents
There is no payment or gift to respondents.
Submissions of information to CMS via the LAN’s contractor from LAN participants will be aggregated, made publicly available, and there will be no personal identifying information collected.
11. Sensitive Questions
There will be no questions of a sensitive nature.
CMS expects to generate four types of information requests to monitor the adoption of the alternative payment models across the U.S. health care system to inform the design, selection, testing, modification, and expansion of innovative payment and service delivery models in accordance with the requirements of section 1115A:
The first type of information request involves collecting self-reported identification information from participants when signing up for the LAN and associated events (LAN Summits, webinars, and other meetings) to understand the types of stakeholders participating in LAN activities (providers, payers, consumers, states, etc.). To date, over 7,100 public and private health care organizations, to include interested individuals, have signed up to participate in the LAN since its launch on March 26, 2015. Each LAN participant will be asked to provide basic identification and opinion information when signing up for the LAN and associated events through collection instruments that CMS estimates will require no more than 10 minutes to complete. Assuming CMS requests registration information for all the events planned during 2022, CMS estimates a total a maximum of 10,000 registration respondents for an annual hour burden of 1,667 (.1667 per response x 10,000 LAN respondents) resulting in an estimated annual cost burden of $75,000 (1,667annual hour burden x $45.00 per hour).
The second type of information request involves conducting simple LAN participant surveys to understand LAN participant opinions, priorities, and issues with respect to how to best increase the adoption of alternative payment models. Surveys will inform decision making about future LAN activities, including LAN Conference sessions, webinar topics,
and feedback on LAN work group ideas. Assuming CMS requests survey information for all the events planned during 2022 with a 30% response rate, CMS estimates a total of 3,000 responses out of 10,000 survey respondents for an annual hour burden of 1,500 (.5 per response x 3,000 LAN responses), resulting in an estimated annual cost burden of $67,500 (1,500 annual hour burden x $45.00 per hour).
The third type of information request will be directed to LAN payers to track the percentage of US health care payments made to providers that are tied to alternative payment models. Requested information may also include estimated counts of US beneficiaries/consumers who are covered by alternative payment models, to include underserved populations. This information will help the LAN understand general market trends and the pace of progress toward alternative payment model adoption across public and private payers and populations. To date, the LAN has conducted six such surveys, from 2016 to 2021, through a collection instrument that health plans have reported requires 25 hours to complete, plus an additional four hours completing informational questions and beneficiaries attributed to these models, for a total of 30 hours. Assuming similar participation in the LAN’s measurement effort as prior years and a cost per response of $45.00 per hour, the annual hour burden will be 3,300 (30 hrs x 110 payers), resulting in an estimated annual cost burden of $ 148,500 (3,300 annual hour burden x $45.00 per hour).
The fourth type of collection will involve information requests intended to track other characteristics of alternative payment model adoption among certain LAN participant types—employers, providers, states, and so on. This information will help the LAN understand how other stakeholders are contributing to market trends and the pace of progress toward alternative payment model adoption across the U.S. healthcare system. An example could be an information request on employer practices around purchasing health care for employees, to include the types of payment models used. To date, approximately 7,100 individuals, employers, payers, consumers, providers, local, state and federal agencies have signed up to participate in the LAN. Each LAN organization type could be asked to provide information related to participation in alternative payment models, depending on the purpose of the information request. CMS estimates these types of collection instruments will require 2 hours to complete. Assuming a total of 10,000 LAN participants responded to these requests and a cost per response of $45.00 per hour, the annual hour burden will be 20,000 (2 hrs x 10,000 participants) resulting in an estimated annual cost burden of $900,000 (20,000 annual hour burden x $45.00 per hour).
Including the estimated $500,000 additional cost to CMS based on data collections in six prior years to carry out this work via the LAN’s contractor, the total annual cost burden across all four information collection types is estimated at $ 1,691,000 (see Estimated Burden Table below). Note that the cost per response assumes $45.00 per hour based on the 2021 GS 14 step 1 hourly rate, which CMS believes is a comparable estimate for the types of employees who will respond to these information requests on behalf of the various types of organizations participating in the LAN.
Estimate of Burden Hours
Type of Collection |
Estimated Annual # of Respondents |
Estimated # of Responses |
Time per Response |
Hours per Response |
Annual Hour Burden |
Cost per Response |
Annual Cost Burden |
LAN Registrations (12.a) |
10,000 |
10,000 |
10 minutes |
0.1667 |
1,667 |
$45.00 |
$75,000 |
LAN Surveys (12.b) |
10,000 |
3,000 |
30 minutes |
0.5000 |
1,500 |
$45.00 |
$67,500 |
LAN Payer APM Tracking (12.c) |
110 |
110 |
30 hours |
30.00 |
3,300 |
$45.00 |
$148,500 |
LAN APM Characteristics (12.d) |
10,000 |
10,000 |
2 hours |
2.00 |
20,000 |
$45.00 |
$900,000 |
TOTALS
|
30,110 |
23,110 |
|
|
26,467 |
$45.00 |
$1,191,000 |
|
|
|
|
|
Estimated |
Annual |
$500,000 |
Federal Cost |
|||||||
|
|
|
|
|
Total Annual Cost Burden |
$1,691,000 |
|
13. Capital Costs
There are no capital costs associated with this information collection.
CMS relies upon an independent contractor to operate the LAN. Based on six years of experience of operating the LAN, and the current proposal and award amount, CMS estimates that the LAN contractor will expend $500,000 annually to carry out the task of developing a measurement and collection methodology to monitor both public and private participation in the LAN and the adoption of value-based alternative payment models across the U.S. health care system.
CMS is requesting 26,467 burden hours in this extension to its current generic clearance. The total number of burden hours already approved (25,917) has been increased slightly because there is increased interest across the US health care system in advancing health equity with APMs and understanding beneficiary participation in APMs with an increased focus on underserved populations. Previously-approved GenICs are listed as follows:
GenIC Title |
Burden Hours Deducted From Total |
(CMS-10620) Tracking the adoption of alternative payment models |
1,250 |
(CMS-10702) LAN Summit Registration Form |
233 |
(CMS-10713) LAN Summit – Total Event Evaluations |
34 |
Tracking the Adoption of Alternative Payment Models (CMS-10620) |
1,350 |
Tracking the Adoption of Alternative Payment Models (CMS-10620) |
1,250 |
Total Hours Actually Used for Information Collections Under Currently Approved ICR: |
4,117 |
Total Hours Remaining for Information Collections Under Currently Approved ICR: |
21,800 |
Requests for self-reported identification information from participants when signing up for the LAN and associated events may be posted publically at the discretion of the LAN. For the most part, this information will be used for internal decision-making purposes.
LAN participant surveys to understand LAN participant opinions, priorities, and issues with respect to how to best increase the adoption of alternative payment models may be posted publically at the discretion of the LAN. For the most part, this information will be used for internal decision-making purposes.
The aggregated results and collection methodologies from information requests to LAN payers to track health care payments made by LAN members who respond to the survey to providers that are tied to alternative payment models will be announced and posted publically through a variety of communication mechanisms—websites, blogs, listservs, publications, and so on. This information will help the LAN and participating payers understand general market trends and the pace of progress toward alternative payment model adoption across public and private payers. d) The aggregated results and collection methodologies from information requests intended to track other characteristics of alternative payment model adoption among certain LAN participant types (employers, providers, states, and others) may be announced publically through a variety of communication mechanisms—websites, blogs, listservs, publications, and so on. This information will help the LAN understand how other stakeholders are contributing to market trends and the pace of progress toward alternative payment model adoption across the U.S. healthcare system. However, this information may only be used for internal decision-making purposes, depending on the specific information request.
17. Expiration Date
CMS does not oppose the display of the expiration date.
The use of statistical methods does not apply for the purposes of this form.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Generic Clearance for the Health Care Payment Learning and Action Network |
| Subject | Supporting Statement for Paperwork Reduction Act Submissions – Part A |
| Author | CMS |
| File Modified | 0000-00-00 |
| File Created | 2022-02-26 |