Course
How CMMI Rulemaking Works
A civics course for the value-based care policy process: the statutory authority behind the Innovation Center, how models are designed and announced, the notice-and-comment rulemaking process, how to participate effectively, and how models expand or end.
By the end of this course, you will be able to:
- Distinguish statute, regulation, and sub-regulatory guidance, and explain why the level matters
- Describe the authority that lets the Innovation Center test and expand payment models
- Navigate a proposed rule and find the provisions and questions worth responding to
- Write a comment letter that an agency is obligated to address
- Explain why so few models are ever certified for national expansion
Foundations of Federal Health Rulemaking
The three levels of federal policy, the Section 1115A authority behind the Innovation Center, and the cast of institutions that shape a model's life.
How a Model Is Born
How CMMI decides what to test, the consequential choice between mandatory and voluntary participation, and how models are actually announced.
The Rulemaking Process
The notice-and-comment process that gives the public a legally meaningful voice, how to read a proposed rule efficiently, and how the comment period works.
Participating Effectively
Writing a comment letter that lands, the other levers beyond comments (coalitions, the advisory commissions, Congress), and following a rule through to implementation.
The Life and Death of a Model
How models are evaluated, the rare certification that lets one expand nationally, the ways models end, and how to become an informed, nonpartisan participant.