Program merges with MACRA as Advanced APM
The Centers for Medicare & Medicaid Services’ (CMS) Comprehensive Primary Care Plus (CPC+) model is building on the foundations laid by the CPCI demonstration project. CPC+ is merging with MACRA as a designated Advanced Alternative Payment Model and carries a medical home designation as well.
The framework, timelines and practice application process for CPC+, as launched by CMS just prior to the issuance of the MACRA proposed rule, can be found here. Our analysis of the proposed rule can be found here.
The next level of assessing this multi-payer initiative is partly dependent on the ability to adapt and grow within the defined Track 1 and Track 2 frameworks, which bring different levels of risk and reward. As a value-based care initiative, there is a trio of foundations to consider.
1. Understand the selection process
The selection of participating practices for CPC+ includes diversification based on a few key factors:
- System affiliation
- Patient characteristics
- Geographic location (e.g. rural/urban)
- Practice size
- Practice engagement with students, residents or other trainees
- Percentage of coverage of practice population by CPC+ payers
CPCI focused on seven geographical regions with 38 payers and 500 practices. Expansion is the goal, as CMS hopes to attract 20,000 providers from 5,000 practices for CPC+.
2. Hone in on the multi-payer strategy
The multi-payer strategy is possibly the most interesting element in the CPC+ plan. CMS will coordinate with payers who share a common interest in strengthening primary care and seek partners from Medicaid FFS, Medicare Advantage Plans, Medicaid managed care, and commercial health insurers to engage CPC+ practices.
CMS is also seeking vendor commitments for Track 2 via Memorandums of Understanding submitted with practice applications. Payer signup is being pursued through June 1, then practices will be asked to apply beginning July 15. CMS’ defined framework to assess payer proposals cuts across three important segments, as defined below:
At an operational level:
- Commit to pursuing private arrangements with practices participating in both Tracks 1 and 2 of CPC+ for the model’s full duration
- Provide improved non-fee-for-service support to allow practices to meet the extended goals of the care delivery model
- Offer an opportunity for a performance-based incentive payment
- Align with Medicare in Track 2 to change the cash flow mechanism from fee-for-service to at least a partial alternative payment model before the end of the first performance year
At a data sharing level:
- Share attribution methodologies
- Supply participating practices with practice- and patient-level data about cost and utilization for their attributed patients through reports (or other methods) in a timely manner
- Provide CMS with practice and patient-level data to be used for monitoring and evaluation
In terms of quality measurement:
- Align practice quality and performance measures under those defined by the CMS model
3. Focus on the practice-health IT vendor relationship
CPC+ also sheds light on the important relationship shared between physician organizations and health IT vendors—and the supporting role those vendors play in improving the infrastructure in those practices. CMS outlined the following as some of the key requirements in the application:
- Identifying and flagging patients with complex needs
- Producing and displaying electronic clinical quality measure (eCQM) results at the practice level to support continuous feedback
- Assessing patients’ psychosocial needs and inventory resources and support those needs
- Documenting and tracking reported patient outcomes
- Enabling practices to assign each patient to a care team or practitioner and sort and review those patients by assignment
- Establishing a patient-focused plan to guide care
By pushing increased uniformity and depth in the health data capture and transmission process, CMS aims to help practices tailor actions to benefit the varied needs of parents and facilitate better care at an individual level.
As various players continue to analyze the CPC+ proposals, there are still questions that need to be answered to drive the program’s success. Collaboration and openness will be key to work out the bugs in the system, a sentiment echoed by Steven J. Stack, MD, president of the American Medical Association: “The American Medical Association has urged CMS to adopt several of these improvements as it designed the next generation of advanced primary care models. This new model holds promise for patients, and we look forward to working with CMS on its continued refinement and implementation.”