I think the factors and discussion outlined here apply to all payers transitioning from FFS to value. The bottom line is that you can only do so much with the FFS chassis as the foundation to your value programs. For commercial payers, this presents an important problem that is often not discussed… benefit design and translating the value to purchasers. In many cases the entire business model, from product to distribution channel (think consultants and brokers) to large employers, is based on a measurement of value based on a discount of charges. This archaic metric persists but is buried within the overall process and is only rarely discussed by those trying to transition to value. Employers need to insist on a more contemporary definition of value from their consultants and the plans.