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There have been a number of unprecedented regulatory flexibilities issued by the Centers for Medicare and Medicaid Services (CMS) in recent weeks given the COVID-19 pandemic, done with the intention of easing the burdens on the health care system to be more responsive to our patients’ needs. But one issue that has been left in limbo is the status of a number of value-based programs at CMS and its Center for Medicare and Medicaid Innovation (the Innovation Center). Where possible by regulatory action, the Department of Health and Human Services should suspend all down-side risk mechanisms in alternative payment models given the current mass scale disruption of the US health care system caused by the novel coronavirus.
There are three major reasons why suspension of financial risk is warranted during this time of unprecedented challenge. First, policies exposing providers to financial risk during the pandemic are at odds with the national interest, particularly given the declaration of a national emergency. Second, such risk-related policies are no longer equitable among health care providers during the pandemic. Third, methodologically, the policy-related hypotheses informing the rationale and design of down-side risk mechanisms no longer hold true. Therefore, the related evaluations of those policy hypotheses are now subject to a myriad of threats to internal validity due to the effects of the pandemic, severely compromising the quality of inference that can be drawn from down-side risk mechanisms.