Formal Comments on Medicare and Medicaid Innovation Center RFI

November 20, 2017


Ms. Amy Bassano

Acting Deputy Administrator for Innovation and Quality and Acting Director of the Center for Medicare and Medicaid Innovation (CMMI)

U.S. Centers for Medicare & Medicaid Services

7500 Security Boulevard

Baltimore, MD 21244


Re: Innovation Center New Direction Request for Information (RFI) posted Sep 20, 2017


Dear Ms. Bassano:

Partners for Better Care (“Partners”) appreciates the opportunity to comment on the Innovation Center New Direction Request for Information (RFI) on a new direction to promote patient-centered care. As a partnership of patient advocacy organizations and a diverse group of healthcare stakeholders, including industry and payers, representing more than 100 million people living with debilitating conditions, we support the Center for Medicare & Medicaid Innovation’s (CMMI) goal of fostering an affordable, accessible healthcare system that puts patients first. Partners is pleased to provide feedback on the informal Request for Information (RFI) on a new direction to promote patient-centered care and test market-driven reforms that empower beneficiaries as consumers, provide price transparency, increase choices and competition to drive quality, reduce costs, and improve outcomes.

Partners for Better Care advocates for the next generation of health care based on key principles of patient-centered quality care, availability, transparency and affordability. Our members – including Aetna, AIDS United, American Liver Foundation, Amputee Coalition, Autism Speaks, Christopher & Dana Reeve Foundation, The diaTribe Foundation, Genentech, Hemophilia Federation of America, Juvenile Diabetes Research Foundation, The MAGIC Foundation, Michael J Fox Foundation for Parkinson’s Research, National MS Society, National Organization for Rare Disorders, National Patient Advocate Foundation, Novo Nordisk, Obesity Action Coalition and United Cerebral Palsy – advocate for those in need based on expert analysis, sophisticated services, and the experiences of the communities they represent. Together, Partners goes a step further and proposes solutions to improve health care for all Americans.

As you know, high-quality medical care is available in the United States, but many Americans are unable to access the care they need. Many individuals and families coping with a chronic or life-threatening condition live paycheck to paycheck, leading them to question when their health is “bad enough” to justify the costs of treatment. However, there are innovative models that would help people – including high-need patients with multiple chronic conditions and functional limitations – receive care to improve outcomes and reduce costs.

CMMI’s new model design principles are laudable areas for collaboration and innovation, and we believe the principle of patient-centered care to, “empower beneficiaries, their families, and caregivers to take ownership of their health and ensure that they have the flexibility and information to make choices as they seek care across the care continuum” is extraordinarily important. Moreover, patient-centered care is not just critical in one category but for any and all new models of care.

Based on extensive opinion research and policy analysis, Partners for Better Care members worked together to establish a core set of principles contained in our nonpartisan Patient Charter — a broad roadmap for the next generation of health care, The Patient Charter starts with, “the need for patients to have an active and formal role in health system transformation including payment and delivery system reform; Systemic efforts to contain costs, assess the value of care and treatment, and generate the best outcomes at a reasonable cost should be patient-centered.”

We firmly agree that improving quality and reducing costs are imperative for patients and the health system, but that can only be accomplished when patients are included in the discussion and development of those models.

We are pleased that patient-centered care is a principle through which the Innovation Center will approach new model design, and we urge CMMI to take two additional steps. 1.) Patient-centered care must be at the top of the priority list and 2.) CMMI must ensure patient-centeredness is imbedded in all new models. To do this, Partners and its membership believe patients must be at the table. As experts on patient-centered care, Partners and its members would be pleased to serve as a resource to CMMI as it develops new models.

Partners for Better Care believes access to affordable, patient-centered care is critical and we laud the effort you are leading to test new models of care. We will continue to participate through discussions, recommendations, and analysis of proposed new models. Partners and its members look forward to working with CMMI to ensure that changes to the health system work for all Americans, especially those living with debilitating conditions.

If you have any questions or need any further information relating to our comments, please do not hesitate to contact me at


Mary Richards

Executive Director

Partners for Better Care