The Maryland Primary Care Program (“MDPCP”) is an unprecedented opportunity for certain health care providers and supporting entities to receive compensation for their efforts to coordinate care and reduce potentially avoidable care by putting care managers and other assistance in the provider office.

This summer, the Centers for Medicare & Medicaid Services (“CMS”) will accept applications from Maryland primary care practices and care management entities (referred to in the program as “Care Transformation Organizations” or “CTOs”) for participation in the MDPCP on an annual basis for 5 years beginning January 1, 2019.  Once selected, MDPCP practices will be assigned to 1 of 2 tracks, depending on the level of care coordination that will be provided. 

CMS will pay participating primary care practices and CTOs a risk-stratified per-beneficiary per-month Care Management Fee as well as an at-risk Performance Based Incentive Payment on a per-beneficiary per-month basis, which must be repaid to CMS by participants that fail to meet the applicable utilization and quality targets. Primary care practices that are assigned to the more advanced Track 2 of the program will also receive a comprehensive primary care payment. 

Practice Eligibility

Eligible primary care practitioners include those who specialize in general practice, family medicine, internal medicine, obstetrics and gynecology, pediatric medicine, geriatric medicine, and psychiatry.  Among other requirements, eligible practices must: (1) be enrolled in Medicare under a single Taxpayer Identification Number; (2) currently provide services to a minimum of 125 Medicare fee-for-service beneficiaries; (3) use a certified electronic health record system; and (4) participate in the Maryland health information exchange (CRISP).  Applications must be submitted by the legal entity that operates the practice, and a separate application must be submitted for each practice location.

Certain providers, such as concierge practices, rural health clinics, and Federally Qualified Health Centers, cannot enroll.  Although there are some exceptions, participant practices may participate in other CMS initiatives, including being part of an Accountable Care Organization (“ACO”) or participating in Tracks 1, 2 or 3 of the Medicare Shared Savings Program.  However, dual participation may affect certain payments under the MDPCP.  In addition, although participation in MDPCP may enable practices to qualify as an Advanced Alternative Payment Model and receive certain incentive payments under MACRA, practices with 50 or more “eligible clinicians” will not so qualify.

CTO Eligibility

ACOs, management service organizations and clinically integrated networks may qualify to serve as CTOs.  Participating physician practices are not required to join a CTO, but practices will likely find it easier to meet the performance metrics of the MDPCP if they are aligned with a CTO.

Timing
Applications for CTOs and practices must be filed no later than July 23 and August 31, 2018, respectively.

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