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Comments: Direct Contracting—Geographic Population-Based Payment Model Option

General Comments
As with all models that could change how people with Medicare access, pay for, or understand their health care, the first step is to ensure that all beneficiaries have the same consumer protections, including limitations on balance billing, conditions on private contracting, and no increase to out-ofpocket costs. We are heartened to see the RFI reiterate that Medicare FFS beneficiaries aligned to DCEs participating in the Geographic PBP model option would retain all of their Original Medicare benefits, including freedom of choice of any Medicare provider or supplier, even if the provider or supplier does not have an arrangement with the DCE.

As with all models that are based on increasing consumerism and shopping, this model must have strong guardrails and fail-safes to ensure that the choices beneficiaries make cannot lead to catastrophic outcomes for their health or financial stability. Overemphasis on shopping can create a system where only the savviest consumers get a reasonable deal and everyone else struggles to get their needs met. More must be done to protect against this risk.

While we were pleased to see that CMS sought feedback through the initial RFI and later stakeholder engagement and appreciated the opportunity to respond to the initial RFI, it is unclear whether beneficiaries and their representatives have continued to play a role in the design process. As we stated in the RFI and in our “Consumer Protections in New Medicare Payment and Delivery Models: A Checklist,” with the AARP Public Policy Institute, models need early and ongoing input from consumer stakeholders to ensure important considerations are part of their very foundations.1

Beneficiaries, families, caregivers, and advocates can provide insights into how to effectively and appropriately communicate with patients, ensure that model evaluation draws on metrics relevant to patients and their families, and help identify ways to avoid inappropriate consumer incentives…

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