On June 8th, the Center for Medicare and Medicaid Innovation (CMMI) announced its intention to test a new voluntary payment model for primary care practices—Making Care Primary (MCP)—in eight states, including New York.
MCP is an advanced primary care model in the tradition of CMMI’s previous primary care models, such as the Comprehensive Primary Care (CPC) and Primary Care First (PCF) designs. Like these models, MCP offers a pathway to an enhanced, capitated Medicare primary care payment—but it reflects the new priorities of the Biden Administration and CMMI’s strategic plan in several important ways:
- Duration: The MCP model is planned to launch in July 2024 and last for a full 10.5 years, through the end of 2034. This time horizon, dramatically longer than previous models, offers the prospect of stable populations and payment benchmarks, allowing practices to initiate long-term reforms.
- Multipayer approach: The MCP model is explicitly intended to align with State Medicaid programs, and the eight states who will participate have agreed to establish aligned Medicaid initiatives—although details remain to be released. CMMI also intends to work with other private payers where possible. This will make it significantly easier to achieve the critical mass of patient panels needed to justify investment in transformation, particularly for practices whose patient populations are majority Medicare and Medicaid.
- Health equity: The MCP model will provide prospective funding outside of primary care reimbursement for “enhanced services,” such as care management and screenings to help address health-related social needs (HRSN). The model is also intended to deploy new social risk adjustment methods for some portion of its payments.
Compared to CMMI’s Accountable Care Organization (ACO) initiatives, MCP is expected to have a more granular and specified care management model and a focus on relationships with non-medical providers, while featuring relatively limited downside risk for total cost of care. Combined with its extended on-ramp, MCP is designed to be more appealing for practices that have been reluctant to enter past CMMI models.
Below is SPG’s summary of the information that has been publicly released so far – as always, please reach out to us with any questions you’d like to discuss.
Model Design
The MCP model is composed of three tracks, reflecting varying levels of experience with advanced primary care. Participants may choose the track they enter at, although Track 1 will only be open to applicants with no prior value-based experience.
- Track 1: A fee-for-service (FFS) payment model with quality bonuses and additional infrastructure funding.
- Participants will begin to develop care management capabilities and conduct HRSN screenings.
- Track 2: A 50/50 mixed FFS and capitated payment model with increased quality bonuses and additional, but more limited, infrastructure funding.
- Participants will implement care management and develop referral relationships with HRSN service providers, behavioral health providers, and specialists.
- Track 3: A fully capitated payment model with further increased quality bonuses and additional, but even further limited, infrastructure funding.
- Participants will implement quality improvement frameworks and deepen their relationships with other providers.
Eligible Providers
The MCP model will be piloted in eight states: Colorado, Massachusetts, Minnesota, New Mexico, New Jersey, New York, North Carolina, and Washington.
To be eligible for MCP, primary care providers must:
- Be enrolled in Medicare;
- Bill for health services furnished to at least 125 attributed Medicare beneficiaries;
- Have the majority of their primary care sites physically located in an MCP state.
Notably, CMMI is encouraging Federally Qualified Health Centers (FQHCs) to participate in MCP, and they will have access to upside-only performance incentives.
Organizations that are ineligible to participate include:
- Rural Health Clinics;
- Current participants in PCF or the ACO REACH model;
- Concierge practices (practices that collect an access fee from participants);
- Grandfathered Tribal FQHCs; and
- After the first six months, current Medicare Shared Savings Program (MSSP) participants.
Application and Timeline
CMMI plans to release the Request for Applications (RFA) for MCP later this summer. The model’s anticipated start date is July 1, 2024.