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Regulatory Alignment

As Vermont moves forward with health system transformation, the Board has begun reviewing its regulatory processes with the goal of aligning them more fully with each other and with the Board’s statutory purpose, in particular improving the health of the population and reducing the per-capita rate of cost growth while ensuring access to and quality of health care. 

Regulatory Alignment White Papers – Discussion Drafts

This series of three white papers considers five core GMCB regulatory processes: (1) All-Payer Model (APM) Regulatory Responsibilities (Medicare ACO Program Design and Benchmark Rate Setting); (2) Accountable Care Organization (ACO) Oversight; (3) Hospital Budget Review; (4) Health Insurance Premium (Rate) Review; and (5) Certificate of Need (CON).

The first paper lays out each of the regulatory processes in its current state.

The second paper considers possible changes to the GMCB regulatory timeline to improve alignment.

  • GMCB Regulatory Alignment White Paper, Part 3: Options for Policy Alignment (to be released in early 2021)

The third and final paper will review four key areas for policy alignment: (1) financial measures, (2) quality measurement, (3) delivery system roles and responsibilities, and (4) risk and reserves.


This white paper series aims to improve the Board’s ability to make decisions consistently across regulatory processes and ensure appropriate assessment of regulated entities in a reformed payment and delivery system environment. Below are specific GMCB alignment goals:

  • Streamline GMCB oversight to ensure regulatory processes inform one another where appropriate and achieve alignment on key policy issues (e.g., aligning health care cost growth with overall economic growth and connecting hospital budget decisions to both health insurance premium rate review and ACO oversight);
  • Develop measures, where feasible, to allow for comparisons across GMCB regulatory processes; and
  • Envision future GMCB regulatory structures as Vermont continues to shift from fee-for-service to population-based payment models.


In developing this series, GMCB surveyed regulated entities and other stakeholders; held a stakeholder focus group; and gathered data about current processes, challenges, and considerations for future regulatory refinements or changes. GMCB is soliciting comment on Parts 1 and 2 of this white paper series from stakeholders and the public during Summer 2020.