On October 23, 2014, the Centers for Medicare & Medicaid Services ("CMS") announced the Transforming Clinical Practice Initiative ("TCPI"), a new initiative aimed at supporting clinicians in developing comprehensive quality improvement strategies through collaborative learning networks. As part of the TCPI, CMS will award cooperative agreement funding to facilitate the development of two network systems—Practice Transformation Networks and Support Alignment Networks. CMS envisions Practice Transformation Networks as peer-based learning networks that encourage clinicians in achieving practice transformation through coaching, mentoring, and other assistance initiatives. Support Alignment Networks would provide the infrastructure to support Practice Transformation Networks and clinician practices to help identify evidence-based practices and scale them nationally throughout the health care delivery system. Applicants may be funded for one of the two models only. CMS intends to invest $840 million over the next four years to support the TCPI to ensure that participating clinicians lead the efforts in creating positive change for the health care industry as it moves from volume-based to patient-centered quality care models. 

CMS offered examples of possible applicant initiative strategies, including: (i) providing physicians with better access to patient information; (ii) fostering patient communication with clinician teams; (iii) improving care coordination across providers; and (iv) utilizing electronic health records daily to analyze quality and efficiency data.

We believe the Practice Transformation Networks, which will receive most of the CMS funding (up to $670 million), will be of particular interest to many of our provider network, hospital and health system, and large physician practice group clients that have already commenced clinician practice transformation efforts. CMS anticipates awarding 35 cooperative agreement awards ranging from $2 million to $50 million under the Practice Transformation Network model in late spring 2015. CMS will award Practice Transformation Network funding to successful applicants that propose compelling means to assist clinicians in transforming their practices and achieve the TCPI's goals, which include, without limitation: (i) building an evidence base on practice transformation; (ii) improving outcomes for Medicare, Medicaid, and CHIP beneficiaries; (iii) reducing unnecessary hospitalizations and overutilization of other services for beneficiaries; (iv) sustaining efficient care delivery for beneficiaries; and (v) generating savings to the federal government through reduced health program expenditures. 

Organizations with preexisting relationships with multiple clinician practices (primary care and/or specialists) and data-sharing capabilities are eligible to apply for Practice Transformation Network funding. Importantly, CMS desires to structure the Practice Transformation Network model to avoid overlap with other CMS comprehensive practice transformation initiatives, such as the Medicare Shared Savings Program and the Pioneer ACO program; therefore, CMS indicates that it will not fund proposals replicating models it is testing currently in other initiatives. 

Applications for both TCPI models are due no later than January 6, 2015. Although not required to do so, applicants are highly encouraged to submit nonbinding letters of intent to apply by November 20, 2014. There are a number of applicant eligibility requirements and award restrictions under both TCPI models. Jones Day will continue to monitor developments with the TCPI and is available to provide assistance to interested parties in applying for funding.