CMMI Introduces New Multi-State Initiative Focused on Enhancing Primary Care Delivery

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Foley Hoag LLP - Medicaid and the Law

Background
CMMI was established to test innovative payment and service delivery models expected to reduce expenditures and preserve or enhance care quality under Medicare, Medicaid, and the Children’s Health Insurance Program. Over the last decade, CMMI has tested a variety of models, including several primary care models. In 2021, CMMI issued a Strategy Refresh to chart a new direction, a key element of which is to move all Medicare beneficiaries into accountable care models by 2030, as well as to increase model participation among safety net providers. This new model seems designed to achieve these aims, as a key goal of the model is to “create a pathway for primary care organizations and practices – especially small, independent, rural, and safety net organizations – to enter into value-based care arrangements.”

Model Goals
The goals of the MCP are to:

  1. Ensure patients receive primary care that is integrated coordinated, person-centered, and accountable;
  2. Create a pathway for primary care organizations and practices to enter into value-based care arrangements; and
  3. Improve the quality of care and health outcomes of patients while reducing expenditures.

The MCP Model is also designed to address and improve health equity—another goal of CMMI’s Strategy Refresh—through payment adjustments for clinical indicators and social risks, and by requiring participants to develop a health equity plan to identify and reduce disparities and implement health-related social needs (HRSN) screening and referrals.

Geography
The MCP Model will be tested in Colorado, Massachusetts, Minnesota, New Jersey, New Mexico, New York, North Carolina, and Washington.

Participants
Participants will be legal entities in the included states that are enrolled in Medicare and bill for health services furnished to a minimum of 125 Medicare beneficiaries. Consistent with CMMI’s aim of enrolling safety-net providers, the focus is on obtaining participation by primary care providers, Federally Qualified Health Centers (FQHCs), Rural Health Clinics, ACO REACH Participant Providers, and other providers. The MCP Model will also include multi-payer alignment, allowing for participation by state Medicaid agencies and other payers.

Model Design
The model will have a progressive three-track approach based on the participant’s relative experience in value-based care. Each of the tracks involve increasing care transformation requirements, the opportunity to earn increased financial rewards for improving patient health outcomes and, as outlined below, increasing levels of financial risk:

  • Track 1: CMS provides financial support to building infrastructure and advanced care delivery capabilities, while the participant remains in fee-for-service (FFS).
  • Track 2: Includes hybrid payment options (a blend of prospective, population-based payments and FFS), with lower levels of CMS financial support.
  • Track 3: Includes fully prospective payments, with the lowest level of CMS financial support.

Model Duration
The model will run for 10.5 years starting on July 1, 2024. 

Additional Information
CMS published a press release and a website with additional information about the model. CMS plans to release a Request for Applications (RFA) later this summer, which will include additional details regarding the model, as well as information regarding how to apply to participate.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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