FR60day_CMSresp8-2-13

CMS Response to Public Comments Received Regarding Planned Information Collection
for the Evaluation of the Multi-payer Advanced Primary Care Practice Demonstration
(Document Identifier: CMS-10479)

The Centers for Medicare & Medicaid Services (CMS) received one comment from the public in
response to a summary of proposed information collection published in the Federal Register on
April 29, 2013 regarding the evaluation of the Multi-payer Advanced Primary Care Practice
(MAPCP) Demonstration (Document Identifier: CMS-10479). The commenter was a coalition of
consumer organizations that described specific patient-centered principles, strategies, policies,
and practices that they believe are important features of the medical home model, and
recommended considering addressing these areas in the evaluation of the MAPCP
Demonstration.
Below we summarize this commenter’s feedback about important components of the medical
home model and our responses. We note in these responses that the information collection that
prompted the April 29, 2013 Federal Register notice consists of focus groups to be conducted in
late 2013 and 2014; subsequent information collections (e.g., beneficiary survey) covering other
types of data that will be collected as part of this evaluation are expected to be described in
future OMB information collection requests and their accompanying Federal Register notices.
The commenter’s feedback has not only been useful to MAPCP evaluators in revising the focus
group protocols, but will also help inform future information collections involving the survey of
practices participating in the MAPCP Demonstration and site visit interviews conducted in future
years. Our responses to the commenter’s feedback are as follows:
1. Advanced primary care must assure ready access to care and consultation with patients
and family caregivers outside of regular business hours.
Response: The focus groups planned as part of the evaluation of the MAPCP Demonstration
will examine patient and caregiver experiences with efforts to assure ready access to care for
Medicare and Medicaid beneficiaries, dual eligibles, and other special populations. The
current focus group protocols (referenced in the attached tables) include general questions to
focus group participants about whether and what steps are being taken to improve access,
including scheduling appointments and methods for contacting providers and other practice
staff. We have added a few questions and/or probes to our focus group protocols to obtain
more specific responses from focus group participants on this topic. In addition, future
administration of a beneficiary survey as part of the MAPCP Demonstration evaluation will
address patient experiences with access to care.
2. Focus groups should assess whether there is effective communication with Medicare
and Medicaid beneficiaries.
Response: The focus group protocols will examine patient and caregiver experiences with
efforts to improve communication with Medicare and Medicaid beneficiaries, dual eligibles,
and other special populations. The current focus group protocols (referenced in the attached
tables) include general questions to focus group participants about whether and what steps
are being taken to improve communication. We have added a few questions and/or probes to

1

our focus group protocols to obtain more specific responses from focus group participants on
this topic. In addition, future administration of a beneficiary survey will address patientprovider communications.
3. Care coordination should be focused on, with specific emphasis on the use of
multidisciplinary care teams to coordinate care obtained from physicians, hospitals,
home care agencies, nursing homes, and community resources. Also, specific
mechanisms that support transitions across care settings, including discharge from
hospital to home, should be focused on, with appropriate involvement of the patient’s
primary care provider.
Response: The focus group protocols will examine patient and caregiver experiences with
efforts to improve care coordination for Medicare and Medicaid beneficiaries, dual eligibles,
and other special populations. The current protocols already include general questions about
what steps are being taken (if any) to improve care coordination and care transitions,
including questions about whether the practices are using care coordinators, hiring additional
staff to help with care coordination and transitions, and whether/how health information
technology (HIT) is being used to facilitate care coordination and transitions. Also, future
administration of a beneficiary survey will address additional aspects of care coordination.
4. The commenter recommends that focus group questions seek to elicit feedback on
whether and how family caregivers are being appropriately involved in the care team,
especially where cognitive challenges prevent the patient from fully managing or
engaging in their own care.
Response: The current protocols examine strategies that primary care practices are using to
improve caregiver engagement. We have also added questions and probes to the caregiver
protocol to further address this subject (see attached Table 2).
5. The commenter commends CMS for emphasizing the importance of community
resources, including the solicitation’s identification of integration and coordination with
community resources and allowing payment for community-based resources that
support primary care. The commenter recommends that focus groups seek to elicit
feedback on whether patients are receiving the community-based resources they want
and need when they need them.
Response: The current protocols include questions about timely care team referrals to
community resources. Future administration of a beneficiary survey also will address use of
community resources.
6. The commenter strongly supports aligning health information technology requirements
with the HITECH meaningful use (MU) definition. They encourage CMS to use focus
groups to elicit feedback from patients and their family caregivers about whether
practices are effectively using HIT, both according to the Meaningful Use criteria, but
also going beyond Meaningful Use.
Response: The current protocols include general questions about HIT. We have added
questions and probes about online access to medical records, caregiver use of HIT, and
patient and caregiver experiences with HIT. Future administration of a beneficiary survey

2

also will address patient experiences with HIT. In addition, future site visits will address
effective HIT utilization by practices including meeting meaningful use requirements and
beyond.
7. Patient-centered medical homes have the potential to ensure that the most vulnerable
populations are receiving high quality, coordinated care and reduce disparities. The
commenter recommended that focus groups include a diverse range of participants—
representing Medicare and Medicaid beneficiaries of different racial and ethnic groups,
with different language needs, various types of chronic conditions and health needs, and
disability status—and ask the right questions to identify some important indicators of
whether these patients are getting the care they need.
Response: Focus groups participants will be screened to ensure a diverse sample is selected.
Two focus groups per state will include participants from special populations that are
included or are a main focus of states’ MAPCP initiative, such as patients with multiple
chronic conditions.
The current protocols include general questions about any strategies, policies, or practices
used to meet the needs of vulnerable populations, including: Medicare and Medicaid dual
eligibles; children; racial and ethnic subgroups; people living in rural or inner-city areas; and
persons with chronic illness, mental illness, or disabilities. Future administration of a
beneficiary survey will also address experiences of patients from vulnerable populations.
8. The commenter believes the most effective strategy to achieve truly patient-centered
advanced primary care is to engage patients and their family caregivers collaboratively
not only in their own care, but also at the practice level and system level—in practice
redesign, planning, governance, quality improvement, and evaluation. They note that
focus groups may not be the most effective way to tell CMS whether practices are
engaging patients and families at the practice and system levels, but Medicare and
Medicaid beneficiaries can provide key insights into whether patient-centered medical
homes are systematically and routinely engaging patients and their family caregivers at
the clinical level and in their own self-management.
Response: The current protocols already include general questions about strategies, policies,
or practices used to engage patients and caregivers at the provider, practice, and system
levels. Future administration of a beneficiary survey also will address patient engagement at
the provider, practice, and system levels.

3