CAHC Shares Recommendations with CMS to Shape Future of the Innovation Center, Improve Prescription Drug Access

WASHINGTON, DC (November 22, 2017): The Council for Affordable Health Coverage (CAHC) – a coalition of employers, insurers, brokers, agents, patient groups, and physician organizations which unveiled its Prescriptions for Affordability initiative to address prescription drug costs earlier this year – responded this week to a request for information (RFI) from the Center for Medicare and Medicaid Innovation (CMMI). The RFI solicits stakeholder input on solutions to move the Innovation Center in a "new direction" while improving quality and reducing costs. 

In its response, CAHC calls for testing value-based arrangements (VBAs) in federal health programs, noting that such arrangements allow resources to be more effectively allocated to treatments that provide the most benefit at the lowest cost to consumers and taxpayers.

CAHC also suggested a new pilot program to test how to lower costs for the most expensive patients, noting that just one percent of patients account for 20 percent of health costs, and five percent of patients make up half of all health spending.

To accomplish this, CAHC proposes:

  • Testing three different voluntary value-based arrangement models under Medicare and Medicaid that would pay for: (1) outcomes measured by reductions in hospitalizations; (2) outcomes measured via clinical values; and (3) outcomes based on medication adherence.  
  • Reforming pricing models that inhibit value-based arrangements by offering clear exceptions to Medicaid best price, Average Sales Price, and Average Manufacturer Price reporting, coupled with clear guidance to reduce current ambiguity about how to capture value-based pricing for reporting purposes.
  • Creating regulatory safe harbors in the anti-kickback statute that allow coordination of care between payers, manufacturers, and providers, and allow donations of technology and infrastructure to help make VBAs fruitful
  • Ensuring manufacturer and payer communications about therapy options, including clinical and economic data, are shared pre-and post-market in order to maximize the uptake of VBAs
  • Including an informational and educational component in VBA models and requiring VBA participants to use a consumer engagement plan that includes information technology and provider decision support
  • Allowing Medicare Advantage plans to enroll high-cost beneficiaries (those in the top 15th percentile of spending) into participating MA plans who would provide comprehensive and integrated care management and services through a network of healthcare providers to meet the specialized needs of such beneficiaries. MA plans would be allowed to innovate in the benefits they provide, including providing care management, custodial care, transportation, in-home assistance, and other services that are not otherwise covered by Medicare

CAHC President Joel White released the following statement on the organization's RFI response:

“We must get our arms around the sickest of the sick. Doing so will improve their health while making progress on our fiscal health," said CAHC President Joel White. "Allowing MA plans to provide transportation and other services to treat the causes of avoidable health costs – including social determinants of health – is important and significant. Training resources on the top spenders should have the biggest impact in lowering costs. We have little to lose in testing the model to see what results." 

Click here to read CAHC's full response to CMMI. Learn more about CAHC's Prescriptions for Affordability initiative here, and its medication adherence campaign - Prescriptions for a Healthy America - here


The Council for Affordable Health Coverage (CAHC) is a broad-based alliance with a primary focus: bringing down the cost of health care for all Americans. CAHC promotes policies that lower health costs through increased competition, informed consumers and more choices to help promote access to affordable coverage. Learn more at