In response to a Centers for Medicare & Medicaid Services (CMS) request for information (RFI), the AANS and the CNS provided input on how best to proceed with episode-based payment models. In the letter, the AANS and CNS recommended that in developing episode-based and alternative payment models, CMS should:
- Incentivize, rather than mandate, participation;
- Involve clinical experts;
- Emphasize specialty-developed quality measures and harness the power of clinical data registries;
- Only hold physicians accountable for care decisions in their direct control;
- Abandon one-size-fits-all approaches; and
- Ensure that evaluations of cost simultaneously account for the impact on quality.
The AANS and the CNS also joined the Physician Clinical Registry Coalition in responding to the RFI, urging the agency to encourage the meaningful use of clinical data registries in any future episode-based payment model. Accordingly, the letter recommended that meaningful use of registry data should be one of the cornerstones of any innovative quality-based payment program.
