A new letter signed by 21 CT consumer advocates to the SIM committee provides more clarity on previous concerns and raises others that have surfaced in the SIM draft plan. SIM is the state’s newest plan to radically reform health care delivery and payment across the entire state. Previous concerns, raised in our August letter to SIM leaders, included potential incentives in the proposed payment system to stint on necessary care for patients’ health and healing. Advocates have urged the committee not to reward stinting — to include monitoring for inappropriate under-treatment and deny shared savings payments that are generated by denying needed care. SIM leaders say they are studying the concept and will approach the SIM steering committee about the idea. The letter repeats concerns that independent consumer advocates have not been represented on the committee. Also included in the August letter and only partially addressed to date has been a lack of transparency in SIM committee and workgroup deliberations, also without independent consumer advocacy representation. A new concern in this latest letter, revealed in the latest SIM draft, includes the potential for downside risk in Medicaid – requiring providers to share losses on patients that end up costing more than analytic models estimate they should have. Advocates are very concerned that downside risk, or any disproportionate incentives to reduce care under any payment model is troubling in any population, but could especially jeopardize the recent hard-won progress in improving care and provider participation in Medicaid. The SIM draft plan was released Nov. 1st and is open for public comment until Nov. 26th or the end of the month.