1. Our AMA encourages physicians to engage in the development of Physician-Focused Payment Models by seeking guidance and refinement assistance from the Physician-Focused Payment Model Technical Advisory Committee (PTAC).

2. Our AMA will continue to urge CMS to limit financial risk requirements to costs that physicians participating in an APM have the ability to influence or control.

3. Our AMA will continue to advocate for innovative ways of defining financial risk, such as including start-up investments and ongoing costs of participation in the risk calculation that would alleviate the financial barrier to physician participation in APMs.

4. Our AMA will work with CMS, the Office of the National Coordinator for Health Information Technology (ONC), PTAC, interested medical societies, and other organizations to pursue the following to improve the availability and use of health information technology (IT):

a. Continue to expand technical assistance;

b. Develop IT systems that support and streamline clinical participation;

c. Enable health IT to support bi-directional data exchange to provide physicians with useful reports and analyses based on the data provided;

d. Identify methods to reduce the data collection burden; and

e. Begin implementing the 21st Century Cures Act.

5. Our AMA will work with CMS, PTAC, interested medical societies, and other organizations to design risk adjustment systems that:

a. Identify new data sources to enable adequate analyses of clinical and non-clinical factors that contribute to a patient’s health and success of treatment, such as disease stage and socio-demographic factors;

b. Account for differences in patient needs, such as functional limitations, changes in medical conditions compared to historical data, and ability to access health care services; and

c. Explore an approach in which the physician managing a patient’s care can contribute additional information, such as disease severity, that may not be available in existing risk adjustment methods to more accurately determine the appropriate risk stratification.

6. Our AMA will work with CMS, PTAC, interested medical societies, and other organizations to improve attribution methods through the following actions:

a. Develop methods to assign the costs of care among physicians in proportion to the amount of care they provided and/or controlled within the episode;

b. Distinguish between services ordered by a physician and those delivered by a physician;

c. Develop methods to ensure a physician is not attributed costs they cannot control or costs for patients no longer in their care;

d. Explore implementing a voluntary approach wherein the physician and patient agree that the physician will be responsible for managing the care of a particular condition, potentially even having a contract that articulates the patient’s and physician’s responsibility for managing the condition; and

e. Provide physicians with lists of attributed patients to improve care coordination.

7. Our AMA will work with CMS, PTAC, interested medical societies, and other organizations to improve performance target setting through the following actions:

a. Analyze and disseminate data on how much is currently being spent on a given condition, how much of that spending is potentially avoidable through an APM, and the potential impact of an APM on costs and spending;

b. Account for costs that are not currently billable but that cost the practice to provide; and

c. Account for lost revenue for providing fewer or less expensive services.

Policy Timeline

CMS Rep. 10, A-17 Reaffirmed: CMS Rep. 03, I-18, Reaffirmed: CMS Rep. 10, A-19, Reaffirmed: CMS Rep. 3, I-19 Reaffirmed: BOT Rep. 13, I-20