The Cms Innovation Center's Expansion Authority and the Logic of Payment Reform through Rulemaking

Abstract

Many models in the early CMMI portfolio appear not to be amenable to expansion, as their payment component is tenuous. In considering models for expansion, CMS will need to assess their generalizability, codifiability, and political viability as well as whether they saved money. Challenges to CMS in exercising expansion authority include choosing or coordinating among models that target the same beneficiaries, transitioning from distributive mode to potentially contentious rulemaking, and deciding whether APMs will exist as voluntary adjunct payment options alongside traditional fee-for-service payment codes or will supplant certain FFS payment codes on a mandatory basis.