Skip to main content

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

This series of 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).


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. Discussion drafts of the first two white papers were released in Summer 2020 for public comment; the final versions posted above incorporate those comments, which are also available on the GMCB website.