The Medicare Rights Center (Medicare Rights) is pleased to submit comments on the “Alternative Payment Model (APM) Framework, Draft White Paper” developed by the Alternative Payment Model Framework and Progress Tracking (APM FPT) Workgroup of the Health Care Payment Learning and Action Network (LAN).

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 over two million Medicare beneficiaries, family caregivers, and professionals annually.

We applaud the commitments made by the Department of Health and Human Services (DHHS) to transition Medicare away from a payment system that rewards volume to one that prioritizes value-based care. Similarly, we strongly support the ongoing efforts of the LAN to bring together diverse voices, including payers, providers, patients, and more, to align payment and delivery system reform approaches.

We applaud the APM FPT for distilling a clear and usable framework for categorizing APMs with respect to payment risk and quality performance. Yet, we believe the white paper would be significantly strengthened with additional content on patient/person-centered care, consumer engagement and protections, patient-centric quality measurement, and delivery system reforms…