Surgeon Leader to Congress: Make CMMI Test Physician-Developed APMs

In April 11 testimony before the U.S. Senate Finance Committee, American College of Surgeons (ACS) Executive Director and CEO Patricia L. Turner, M.D., M.B.A., said surgeons seeking to move beyond fee for service still find few physician-focused alternative payment models (APMs) available since none of the models submitted to the Physician-Focused Payment Model Technical Advisory Committee (PTAC) have been tested as proposed.



In her tesimony, Turner called on Congress to address cuts already expected in 2025 and do more to make alternative payment models available that incentivize access to timely, high-quality care for all surgical patients. She said that APMs can facilitate better care and could also be used to incentivize physicians to practice in rural or underserved areas.



“Unfortunately, efforts at implementing an Advanced APM were hindered by a breakdown of the process envisioned in MACRA. Along with dozens of other groups, ACS developed and submitted proposals that were reviewed, revised, and evaluated by the PTAC,” she said in her written testimony. 

“Fourteen proposals have been recommended for testing or implementation by the PTAC, but CMS has not tested a single model through the Center for Medicare and Medicaid Innovation (CMMI) as proposed,” she said. “This bottleneck has created a disincentive for stakeholder investment into the development of APMs, as witnessed by the lack of new proposals on the PTAC website since 2020.”

The ACS-Brandeis Advanced APM proposal included shared accountability for cost and quality for defined episodes of surgical care and allowed for the entire care team, including the primary care physician, to work together toward shared goals, Turner explained. “Information on the comprehensiveness of a quality program, along with comparable information on the price of that care, are prerequisites for a valid depiction of the value of care.”

The ACS has supported the development of standardized episode definitions to foster alignment of both price and quality measurement and create shared accountability for the team of providers. Turner said ACS’  proposal would provide the data and incentives necessary to drive value improvement in specialty care. “While it is our impression that Congress has provided the resources to CMS and the Innovation Center that are necessary to stand up and test PTAC-recommended APMs, there is nothing within the law to compel CMS to try out new programs,” she said. “This creates further barriers to those seeking to move to value-based care. Congress should require that at a minimum, some portion of the CMS Innovation Center’s budget be dedicated to testing physician and specialist-developed APMs recommended by the PTAC.”

Most surgeons in the current fee-for-service system are evaluated on measures that do not reflect the care they deliver to patients or the conditions they treat, Turner explained, and the current model of individual, disconnected measures is insufficient to achieve coordinated, patient-centered, high-value care. Turner stressed that the system should incentivize high-quality, coordinated care centered around the patient. Without Congressional action, continued cuts to Medicare will pose challenges to physicians’ ability to provide adequate services and high-quality care to all patients, including those with chronic conditions, she said.

“We believe that medicine should be advancing toward a system that rewards high-quality and value-based care,” Turner testified. “This transformation is under way and would benefit from efficient investments in the partnership between CMS and subject matter experts committed to improving the way quality is measured and incentivized, and by improving the calculus of the physician fee schedule.”

In early 2023, the ACS submitted a programmatic measure, the Age Friendly Hospital Measure, to the CMS Measures Under Consideration (MUC) list to demonstrate how programmatic measures could be implemented in CMS programs, Turner explained. “We are optimistic this measure will be included in the Fiscal Year 2025 Inpatient Prospective Payment System (IPPS) proposed rule and will hopefully be available for hospital reporting in future years.”  

She said the measure considers the full program of care needed for geriatric patients. It incentivizes hospitals to take a holistic approach to the provision of care for older adults by implementing multiple data-driven modifications to the entire clinical care pathway spanning the emergency department, the operating room, the inpatient units, and beyond. The measure puts an emphasis on the importance of defining patient (and caregiver) goals, not only from the immediate treatment decision, but also for long-term health and functional status.