On April 11, 2016, the Centers for Medicare & Medicaid Services (“CMS”) announced a new model for the way Medicare pays many primary care physicians. The Comprehensive Primary Care Plus (“CPC+”) model aims to enhance primary care through care redesign. CPC+ will include two primary care practice tracks with incrementally advanced care delivery requirements and payment options for primary care practices.  CMS is currently soliciting payer proposals to partner with Medicare in CPC+ until June 1, 2016. From July 1, 2016 until September 1, 2016, CMS will publicize the CPC+ regions based on the payers selected and solicit applications from primary care practices within these regions.  Primary care practices interested in this initiative should begin the application for CPC+ now.

Background

CPC+ builds on the foundation of the Comprehensive Primary Care (“CPC”) initiative, a model tested through CMS running from October 2012 through December 31, 2016.  Effective January 1, 2017, CPC+ will enter into a Memorandum of Understanding with selected payer partners to document a shared commitment to align on payment, data sharing and quality metrics throughout the five-year initiative. CPC+ is in conjunction with several other CMS alternative payment model initiatives that are part of a broad effort to reward quality, opposed to quantity, of care.

Details of CPC+

There are up to 20,000 primary care physicians expected to enroll in CPC+ who will receive monthly care management fees that will give the physicians more freedom to deliver care that is appropriate to their patients instead of having to rely exclusively on fees for each service they provide an individual patient. Physicians who see better health outcomes for their groups of patients, as determined by a set of performance data metrics, will keep all or most of those fees, while physicians who fall short will have to repay some of those fees.

Under the model, practicing medical practices will opt for one of two tracks.  Practices in both tracks will make changes in the way they deliver care, centered on key CPC functions: (1) Access and Continuity; (2) Care Management; (3) Comprehensiveness and Coordination; (4) Patient and Caregiver Engagement; and (5) Planned Care and Population Health. In addition to their Medicare fee-for-service (“FFS”) payments, Track 1 practices will receive a care management fee that averages $15 per beneficiary per month. Track 1 is the most similar to the original CPC model, but CMS has refined the eligibility criteria, care delivery requirements and incentive payment opportunities to incorporate lessons learned in the original CPC model.

Track 2 targets practices proficient in comprehensive primary care that are prepared to increase the depth, breadth and scope of medical care delivered to their patients, particularly those with complex needs. In support of this provision of care, payment is redesigned to be a hybrid of FFS paid at the time of the visit and FFS prospectively paid. Track 2 practices will also receive an enhanced care management fee averaging $28 per beneficiary per month to support care management, enhanced to support the more stringent requirements for Track 2 practices and to enable more comprehensive care for their patients with more complex needs.

Practical Takeaway

Practices that are interested in participating in CPC+ should begin to prepare their applications in anticipation of submission beginning on July 1, 2016.  CMS anticipates receiving a high level of applications, so it is critical for practices to ensure applications are completed accurately.