Application Process Opens to Practices
Amid growing consensus that MACRA may delay from its 2017 performance year start, CMS is moving ahead with next year’s launch of the Comprehensive Primary Care Plus (CPC+) program.
Fourteen multi-payer regions and all participating payers were announced August 1, (listed below) and practices can now begin applying through September 15. The provider and practice application form can be found here.
CPC+ is part of MACRA, as one of six Advanced Alternative Payment Models, but certainly can be undertaken on its own. CMS has a deadline of November 1 to produce a MACRA final rule, but can announce MACRA’s fate anytime prior.
Also newsworthy within CPC+ is CMS’ recent announcement that primary care practices can participate in a CMS MSSP ACO and the CPC+ program at the same time.
Offering Track 1 and Track 2 risk levels, practices applying for Track 2 must include a vendor letter of support.
CMS had wanted to reach its goal of 20 payer regions, but has settled for 14 to keep the program on its timeline.
For more information on the risk tracks and payment model, see Wellcentive’s April 22 blog, Grading CPC+. For a detailed review of the care delivery capabilities required for all categories within Tracks 1 and 2, see Wellcentive’s webinar and slides entitled The ABCs of CPC+.
Dual eligibility and payments
Essentially, primary care providers in a CMS MSSP ACO, Tracks 1, 2 or 3, can also participate in CPC+.
Financially, payments can come from both programs, the care management fee only from CPC+, combined with the shared savings incentive payment from the MSSP. (Overall, CPC+ offers a performance-based incentive payment and a care management fee based on Track, for those not participating in an MSSP.)
And of course, there is some fine print.
Overall, beneficiary attribution won’t change in either program. In CPC+, Medicare beneficiaries are aligned prospectively and quarterly, and in MSSP, alignment is annual, so it is possible that some beneficiaries will be attributed to a CPC+ practice but not the ACO that includes that CPC+ practice, or attributed to an ACO but not attributed to a CPC+ practice within that ACO.
CMS has stated it will communicate this process individually with participating practices, and that it reserves the right to counsel applying practices on which CPC+ Track is the best fit.
New risk scoring and HCC code updates
For the CPC+ program, CMS has embarked on a new risk adjustment model for 2017, with the risk adjusted payment based on updated Hierarchical Condition Category (HCC) risk scores.
The new model has separate coefficients for partial benefit dually eligible beneficiaries, full benefit dually eligible beneficiaries and non-dually eligible beneficiaries. The point is to “improve the precision of the payments made to plans, including increases in payments for plans serving full benefit dually eligible beneficiaries,” according to the agency.
More information on the HCC-based risk adjusted payments can be found here.
CPC+ Payer Regions
The 14 regions include:
- 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: Ohio and Northern Kentucky Region
- Oklahoma: Statewide
- Oregon: Statewide
- Pennsylvania: Greater Philadelphia Region
- Rhode Island: Statewide
- Tennessee: Statewide
An array of details and fact sheets on CPC+ vendor support, program details and payer requirements can be found here on the CMS CPC+ web page.