Fewer electronic health record requirements, smaller payment reforms and changing the definition of financial risk are some of the changes suggested by major healthcare groups in response to the CMS request for information on future models at the Center for Medicare and Medicaid Innovation (CMMI).

CMS Administrator Seema Verma, MPH, had requested comments from the healthcare industry beginning in September, promising a “new direction” for CMMI models after policies that, she said, encouraged consolidation under the Obama administration.

“Providers need the freedom to design and offer new approaches to delivering care. Our goal is to increase flexibility by providing more waivers from current requirements,” Verma wrote.

The request came after Verma cancelled two CMMI mandatory bundled payment models which had been set to begin in 2018.

While the full list of comments isn’t publicly available—though CMS said it may post the full comment or a summary—several groups have released the suggestions they sent to CMS.

Here are proposals made by five of the responding organizations:

1. The American College of Physicians said future models should be developed with greater collaboration with groups such as itself: “Stakeholder collaboration should be incorporated into the development, testing, and implementation of alternative payment models (APMs)with a focus on ensuring that those models are truly leading toward improved quality and value that is meaningful not only to payers and clinicians, but also to patients and their families.”

2. The American Hospital Association said the requirement that APMs need to include downside risk to “count” towards the Advanced APM track in the Quality Payment Program should be loosened in order to expand participation through models introduced through CMMI: “The AHA continues to urge CMS to expand its definition of financial risk to include the investment risk borne by providers who participate in APMs and to develop a method to capture and quantify such risk. This approach would enable many of the CMMI models in which significant resources already have been invested to qualify for advanced APM incentive payments.”

3. The Federation of American Hospitals argued, as it has in the past, that mandatory models are outside CMMI’s authority, and future models should not be only be voluntary, but done on a smaller scale: “Advancing Medicare payment policy on such a wide-scale, without the benefit of understanding patient and provider impact through testing on a smaller-scale, puts Medicare beneficiaries and providers at risk.”

4. The Healthcare Information and Management Systems Society (HIMSS) said new models should incentivize the exchange of health information: “ The provision of additional reimbursement incentives to those payment models that demonstrate robust use of secure, interoperable systems should be reviewed. Ultimately, we envision a coordinated and collaborative health system where patients, their families, and their clinicians are all part of the care team.”

5. The Electronic Health Record Association said new CMMI models should be wary of adding new electronic health record (EHR) requirements, which could burden vendors, and instead align new EHR requirements in CEHRT standards rather than in individual payment models: “If additional technology capabilities are needed for a program, aligning those technical needs with criteria included in CEHRT, as opposed to defining ad hoc prescriptive functional requirements, will help reduce vendor burden in developing new features and implementing them in customer systems.”