We hosted an exceptional roundtable with former CMS and CMMI leaders—Kristy Martin, Doug Jacobs, Liz Fowler, and Purva O’Rourke—who pulled back the curtain on how CMS operates, what drives policy, and how providers can productively engage the agency.

Highlights & Takeaways

• CMS culture = mission-first, non-partisan, expert-driven. Career staff see themselves as stewards of Medicare/Medicaid and keep the “trains running” regardless of administration.
• Playbook to engage CMS (no lobbyist required):
• Use public comment periods
• Request meetings
• Attend site visits
• Email program leads directly (staff will often route you to the right person)
• Don’t wait until there’s a compliance issue—build relationships early
• “Listening mode” is normal. During rulemaking windows CMS may not respond in the moment—but silence can mean your input landed and is being weighed.
• Accountable care remains the north star. CMS wants beneficiaries in models where a “quarterback” is accountable for cost and quality, with on-ramps for smaller/rural providers and emphasis on provider-led governance.
• Primary care signals are positive. Recent PFS proposals maintain/expand advanced primary care, CCM/remote monitoring, and navigation codes—an encouraging sign for longitudinal, team-based care.
• Site-of-service migration will continue. CMS is actively evaluating procedures moving from inpatient to outpatient/ASC when safe and cost-effective—stakeholder comments matter here.
• Transparency is advancing. Price-posting requirements and NSA data are maturing; expect a more navigable market over the next few years as datasets standardize and tools improve.
• Behavioral health is moving from “supplemental” to integrated. New codes, broader provider definitions, and ACO/primary-care integration are building blocks—further progress may require Congressional authority.
• AI + burden reduction are live priorities. CMS is exploring AI for fraud detection and administrative simplification; proposals that reduce provider burden are welcome.

Practical “Do / Don’t” from the Panel

• DO:
• Comment on proposed rules
• Share data, outcomes, and real-world constraints
• Introduce innovative models early
• Follow up even if CMS can’t discuss specifics
• DON’T:
• Assume only large systems get heard
• Wait until there’s a problem
• Read “quiet” meetings as failures

Why it matters for MSOs & Health Systems

• Strategy: Align roadmaps with accountable care, primary-care enablement, and behavioral integration.
• Operations: Build capabilities around care management, RPM/RTM, and documentation to capture value under evolving codes.
• Advocacy: Engage both CMS and Congress—some levers (e.g., broader BH coverage, physician payment reform) are statutory.