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BIO Submits Comments Re: HCP LAN APM Draft Framework

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Alternative Payment Model Framework and Progress Tracking Work Group</div>
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Health Care Payment Learning &amp; Action Network</div>
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U.S. Department of Health and Human Services</div>
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200 Independence Avenue, S.W.</div>
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Washington, D.C. 20201</div>
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BY ELECTRONIC DELIVERY</div>
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RE: Alternative Payment Models Framework Draft White Paper</div>
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Dear Alternative Payment Model Framework and Progress Tracking Work Group:</div>
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The Biotechnology Industry Organization (BIO) is pleased to submit feedback in response to the U.S. Department of Health and Human Services&rsquo; (HHS&rsquo;s) Health Care Payment and Learning Action Network&rsquo;s (HCP LAN) &ldquo;Alternative Payment Models Framework Draft White Paper&rdquo; (the &ldquo;Draft White Paper&rdquo;), released on October 22, 2015.1 BIO represents biotechnology companies, academic institutions, state biotechnology centers, and related organizations across the United States and in more than 30 other nations. BIO&rsquo;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&rsquo; 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.</div>

The Biotechnology Industry Organization (BIO) is pleased to submit feedback in response to the U.S. Department of Health and Human Services’ (HHS’s) Health Care Payment and Learning Action Network’s (HCP LAN) “Alternative Payment Models Framework Draft White Paper” (the “Draft White Paper”), released on October 22, 2015.1 BIO represents 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 views the HCP LAN as an important opportunity to participate in the Department’s effort to meet the payment reform goals identified by the Secretary earlier this year: specifically, that by the end of 2016, 30 percent of traditional Medicare payments are tied to quality or value through alternative payment models (APMs) (50 percent by 2018) and 85 percent of all traditional Medicare payments are tied to quality or value (90 percent by 2018).2 In order to meet these ambitious goals, HHS will need to work closely with stakeholders to ensure that efforts to transition from reimbursing for volume to value do not result in unintended consequences that restrict individual patient access to the most appropriate, timely care. The HCP LAN is one such opportunity for ongoing stakeholder input, and BIO supports HHS’s efforts to strengthen this collaborative discussion through the formation of work groups and the launch of public forums. In particular, we applaud the Work Group’s interest in receiving public feedback in advance of finalizing the Draft White Paper. We strongly encourage the HCP LAN, and the Department more generally, to continue and expand this outreach to ensure broad participation.