CMS, MSAs, and credit where credit is due

My post on Monday about the internal memo released by CMS regarding MSA allocations triggered a round of name-calling, motive-assumption, and general nastiness by people in the MSA business furious that I awarded PMSI much of the credit for the change.
That, and/or the change has been described as not material and raising more questions.
Here’s how I put it Monday.
“[MD Kent] Takemoto has been working with CMS for over a year in an effort to revise/revamp/redo the methodology used by CMS to calculate/estimate drug costs in Medicare Set-Aside allocations.
After multiple meetings, lots of analysis (both mathematical and scientific) of drugs commonly used in comp v drugs not commonly used, drug substitution, and plenty of persistence Kent’s efforts have borne fruit…The methodology developed by PMSI and approved last week by CMS is a major step in the right direction.”
I was contacted by several individuals who claimed that they or their organization were at least partially responsible for the revision; I asked each to provide documentation of their activity, noting I’d “be happy to amend my post if necessary.” I’d hasten to add that some correspondents were professional and courteous; others engaged in name-calling and inferred I wrote the post to somehow ingratiate myself with PMSI, or because PMSI is a client, or was somehow duped by PMSI.
Let me address each in turn.
Name-calling – either grow up or shut up.
Clients – As long-time readers are well aware, I ALWAYS note when a client is mentioned on the blog. Therefore, insinuating that I wrote this to aid a client is flat out wrong.
Marketing – I have written complimentary posts about numerous companies and organizations that are NOT clients, including Aetna, Harbor Health, Broadspire, SRS, Progressive Medical, Mitchell, Medata, Datacare; heck, I’ve even written nice things about Coventry. Inferring that I wrote the post to schmooze PMSI, a company I’ve taken to task rather bluntly in the past, reflects poorly on those who would make that inference.
Duped – There’s ample evidence that PMSI did, in fact, help CMS develop solutions to several key issues, solutions that will help the entire industry. Yes, this will certainly help PMSI, as their methodology was approved by CMS; it will also help payers, PMSI’s competitors, and CMS over the long run.
As I stated in the original post, the CMS memo came “After multiple meetings, lots of analysis (both mathematical and scientific) of drugs commonly used in comp v drugs not commonly used, drug substitution…”. I’ve seen research documents, email correspondence, visitor passes, and other materials pertaining to PMSI’s efforts. It is abundantly clear that PMSI and Takemoto expended a lot of effort and brain power to develop a solution.
I spoke with PMSI CEO Eileen Auen about this (Auen is a highly respected and very well regarded executive and a person for whom I have the utmost regard). She verified my understanding of the research and analytical work put into the problem by PMSI, noting the level of effort was commensurate with the result. But what Auen really wanted to focus on was the positive impact of the revision on all payers, and her desire to see the industry working more closely together on this and other issues. As Eileen told me, “others have also worked to advocate for change – we applaud their efforts. Perhaps the lesson out of this, is that the MSA industry should find ways to collaborate more closely (like we have in Pharmacy and Ancillary Service) to drive an industry agenda.”
I asked two of my critics to provide me with documentation of their role in effecting this change at CMS. One said they wouldn’t as PMSI is an HSA client, the other said they would provide such documentation but as of this moment has not.
I’ve no doubt that many individuals and organizations spoke to CMS, sent letters, complained, called, sent emails, and met with individuals at CMS about issues related to MSA allocation calculation bases and methodology. Their efforts and attempts to resolve a very difficult issue are laudable. If any of them played a material role in effecting this change, they have yet to share evidence of that role with me. If and when they do, I’ll review it, give credit where credit is due and write it up for your reading pleasure.
Until then, I stand by my post.
Now – could we please get back to work?