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Implementing PPACA. Gail R. Wilensky Project HOPE July 9, 2010. Many Challenges. ♦ Huge, complex bill. ♦ Many changes affecting . -- State governments -- HHS -- CMS . CMS – The Agency Congress Loves to Hate. A “challenged” organization …. ♦ Agency has been starved for funds
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Implementing PPACA Gail R. Wilensky Project HOPE July 9, 2010
Many Challenges ♦ Huge, complex bill ♦ Many changes affecting --State governments --HHS --CMS
CMS – The Agency Congress Loves to Hate A “challenged” organization … ♦ Agency has been starved for funds -- Equal opportunity abuse by R’s and D’s and by Executive Branch and Congress ♦ Many retirements in last decade -- ing institutional knowledge ♦ Additional funding for implementation -- Only temporary
Additional Challenges for CMS ♦ Recent reorganization/realignment (March 24) -- Reorganizations always cause turmoil/disruption ♦ No confirmed administrator since 2006 ♦ Recess appointment of Don Berwick -- Limits his tenure to 18 months -- Further damages his relationship with R’s
So … Now What? ♦ CMS (and other parts of HHS) are: -- Forming workgroups -- Drafting time-lines for reg production -- Establishing review processes, strategies to resolve disputes -- Meeting on a frequent/regular basis ♦ Making sure adequate resources are focused on “routine” functions -- i.e., running Medicare, overseeing Medicaid
Early 1990’s Experience: RBRVS Passed 11/89, Implementation 1/1/92 Challenges: ♦ RBRVS incomplete when passed ♦ Outreach needs to physician population ♦ Write and post proposed rule -- Internal inconsistencies in the law -- 100,000 responses Outcome: ♦ Final rule/operational changes on time
Much More Challenging Time -- Even More than BBA ♦ Put in place all of the changes for the annual updates ♦ Start many one-time changes ♦ Create a new Innovation Center ♦ Provide oversight for annual Medicaid changes -- home health option, drug rebate changes, various state options
One of Many Thorny Challenges for CMS ♦ Establishing rules/regulation for Hospital Value-Based Purchasing Program -- Regs regarding performance measures, methodology to calculate hospital performance score, methodology to determine amt of incentive-based payments, etc. -- All likely to be very controversial, expect a lot of responses -- Be ready to go by 2012
GOOD LUCK CMS!