On behalf of the NEWDIGS initiative / FoCUS Project, team members submitted comments on the recent CMS Proposed Rule supporting Value-Based Purchasing (VBP) (CMS-2482-P). With active input from an engaged set of our cross-sectoral members, we focused on the Proposed Rule as an important step forward in enabling outcomes-based contracting by addressing several Medicaid Best Price methodology challenges. We encouraged further efforts to promote use of the full range of precision financing solutions by addressing additional barriers for payment over time and subscription approaches. In addition, we suggested a number of areas where additional regulatory clarification or innovation would be helpful in regards to the approaches suggested in the Proposed Rule.
Download a copy of our comment (PDF)