CMS has announced the regions for the newest primary care transformation initiative, Comprehensive Primary Care Plus (or CPC+):
Arkansas: Statewide
Colorado: Statewide
Hawaii: Statewide
Kansas and Missouri: Greater Kansas City Region
Michigan: Statewide
Montana: Statewide
New Jersey: Statewide
New York: North Hudson-Capital Region
Ohio: Statewide and Northern Kentucky Region
Oklahoma: Statewide
Oregon: Statewide
Pennsylvania: Greater Philadelphia Region
Rhode Island: Statewide
Tennessee: Statewide
Demands on the primary care delivery system to achieve quality and cost goals have become increasingly complex and unsustainable. CMS seeks to provide a solution through CPC+, a five-year, multi-payer initiative that will help up to 5,000 practices build a population health infrastructure beginning January 1, 2017.
Here are 5 things to know about CPC+:
- CPC+ will replace the original CPCI model to further bolster the medical home model. CMS has been explicit in their intent to create a model that supports and strengthens primary care delivery. By seeking partnership with regional payers and defining commitment to the model for 5 years, CMS is also signaling this plan to be sustainable and supportive to transition practices from limited infrastructure to medical home.
- Practices can apply to one of two tracks within CPC+. Each track will cap participation at 2,500 or less, leading to a maximum of 5,000 participating practices. Unlike Track 1, Track 2 has explicit requirements around HIT infrastructure, quality and utilization for participating practices, making it better suited for practices with more experience in population health.
- There are incentive payments to build infrastructure and improve care process. The Care Management Fee (CMF) is a monthly, prospective payment paid to the practice for attributed Medicare FFS beneficiaries. This CMF payment will be risk-adjusted to reflect the resources needed for more complex patients. For Track 2 only, Medicare will also pay a portion of a PCP’s Evaluation and Management (E&M) revenue per-beneficiary-per-month quarterly upfront to the practice. Additionally, for both Track 1 and Track 2, practices will receive performance-based payments depending on performance in annual quality and utilization metrics.
- Smaller practices may qualify to avoid MIPS in proposed MACRA regulation: Under the MACRA proposed rule, a practice TIN must have fewer than 50 clinicians to qualify for the 5% Advanced APM bonus starting in 2018. This restriction does not preclude a practice TIN larger than 50 from joining CPC+, it just affects their MIPS status in 2018 and beyond.
- There are some key requirements participating practices must be prepared to meet: Practices will need to develop infrastructure to support a range of activities, from providing care management and population health, patient and family engagement, 24/7 access to care and improved analytics capabilities and health IT use. More information on the requirements can be found on CMS’ website.
For practices with limited infrastructure or exposure to population health, CPC+ may be a great opportunity to invest incentives from CMS into meaningful change in the delivery of health care. For those who have started dipping a toe already in risk-bearing payment models, other routes may have better financial upside. Practices should consider their past and present experience and position to invest in order to choose the most advantageous route forward.
Do you have questions on what CPC+ means for your region? Contact us to speak with an expert.
