Comments Re: Request for Information on Direct Provider Contracting Models

The Medicare Rights Center (Medicare Rights) appreciates the opportunity to comment on the Center for Medicare & Medicaid Innovation (CMMI) Request for Information (RFI) on Direct Provider Contracting (DPC) Models.

Medicare Rights is a national, nonprofit organization that works to ensure access to affordable health care for older adults and people with disabilities through counseling and advocacy, educational programs, and public policy initiatives. Medicare Rights provides services and resources to three million people with Medicare, family caregivers, and professionals each year.

The following comments are informed by our experience assisting people as they navigate the Medicare program. We caution that it is difficult to provide meaningful feedback on potential policies that hinge on specific details unless we see those details. As the RFI is largely silent on such specifics, our comments may recommend guardrails for roads CMMI does not intend to travel, and may fail to fully consider a model the agency does intend to pursue. Therefore, while we are pleased to offer general comments in response to this RFI, we respectfully request opportunities to provide more targeted input through future calls for public comment on the DPC model or models…

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