AAHKS submitted comments to the Centers for Medicare & Medicaid Services (CMS) on its Center for Medicare & Medicaid Innovation (“Innovation Center” or CMMI) New Direction Request for Information (RFI). AAHKS is guided by its three principles: payment reform is most effective when physician-led; the burden of excessive physician reporting on metrics detracts from care; and patient access, especially for high-risk patients, must remain a focus. These principles steered the focus of our comments, which touched on voluntary versus mandatory payment models, empowering beneficiaries, adequate risk adjustment, and excessive physician reporting among other issues. Read the full comment letter.