VIA ELECTRONIC SUBMISSION
March 1, 2014
Patrick Conway, M.D.
Deputy Administrator for Innovation and Quality
Chief Medical Officer
Centers for Medicare & Medicaid Services
Center for Medicare and Medicaid Innovation
7500 Security Boulevard
Baltimore, MD 21244
RE: Request for Information: Evolution of ACO Initiatives at CMS
Dear Dr. Conway:
The Biotechnology Industry Organization (BIO) is pleased to submit the following comments regarding the Request for Information (RFI) on the “Evolution of ACO Initiatives at CMS” released by the Center for Medicare and Medicaid Innovation (CMMI) on December 20, 2013. BIO represents more than 1,000 biotechnology companies, academic institutions, state biotechnology centers, and related organizations across the United States and in more than 30 other nations. BIO’s members develop medical products and technologies to treat patients afflicted with serious diseases, to delay the onset of these diseases, or to prevent them in the first place. In that way, our members’ novel therapeutics, vaccines, and diagnostics not only have improved health outcomes, but also have reduced healthcare expenditures due to fewer physician office visits, hospitalizations, and surgical interventions.
BIO represents an industry that is devoted to discovering new treatments and ensuring patient access to them. Accordingly, we closely monitor payment policies for their potential impact on innovation and patient access to drugs and biologicals. BIO believes that ACOs have great potential to provide better care for individuals, better health for populations, and lower growth in overall expenditures—a three-part aim that BIO fully supports. That said, risk-based models, particularly those involving capitated payment rates, create incentives to undersupply services to control spending, to the potential detriment of patients. BIO is particularly sensitive to the fact that one area in which care is stinted and services undersupplied is with regard to new technologies because the savings associated with these technologies often are not realized within the relevant window of time and their costs are not included in the benchmark. Moreover, while BIO applauds CMMI for seeking public input with respect to the Pioneer ACO program, BIO is concerned that CMMI aims to expand the program after obtaining only limited savings in the first two years, particularly after nine ACOs recently left the Pioneer demonstration.