If CMS proceeds with a proposed transparency rule in its Increasing Organ Transplant Access Model, patient access, quality of care and trust could deteriorate, according to the American Hospital Association.
The IOTA model is a six-year mandatory alternative payment model that began July 1. For the model’s second year, CMS is considering several changes. In a Feb. 9 letter to the federal agency, the AHA said aspects of the model’s design and proposed changes “may decrease access and adversely affect patients’ quality of care.”
The AHA said it is “extremely concerned” about CMS’ proposal to require IOTA participants, such as transplant hospitals, to notify kidney transplant waitlist patients the number of times an organ is declined on their behalf.
Notifying patients of the number of declined organs could not only add administrative burden to transplant programs, but the organization said it might also be “needlessly disheartening” to patients and hurt their relationship with the transplant team.
The AHA said it “strongly opposes this proposal because the administrative complexity of implementing it would far outweigh its potential value to either patients or providers.”
Another proposed change is raising the minimum number of annual kidney transplants required for participation from 11 to 15. The AHA argued that this is too low, adding that the low-volume threshold could include organizations lacking the infrastructure costs needed to participate in IOTA.
While the AHA said the model should be voluntary, its letter stated: “If CMS continues to make participation in the IOTA Model mandatory, we urge it to conduct and publish analyses to determine a [transplant] threshold that ensures statistical significance and effectively mitigates potential impacts of outliers and volatility in cases.”
CMS is also considering including Medicare Advantage beneficiaries in the model. The AHA, which represents nearly 5,000 hospitals, health systems and other healthcare organizations, urged caution on significant changes to the IOTA’s payment structure.
“In the event that CMS decides to calculate the performance-based payments based on [Medicare Advantage] as well as [Medicare fee-for-service] patients, the AHA strongly opposes any decrease in the maximum upside risk payment,” the letter said. “Even at its current level ($15,000), the maximum amount likely would not cover a hospital’s costs and resources expended to participate in the IOTA Model.”
The AHA also pushed back on potential changes to performance score ranges and some transparency requirements.
Read the AHA’s letter here.
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