CMS Announces CMMI Milestones and Updates

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CMS recently announced updates and milestones for several programs run by the Center for Medicare and Medicaid Innovation (CMMI). CMMI is the internal CMS agency responsible for developing and testing new health care payment and delivery models, including implementation of the Quality Payment Program enacted as part of the Medicare Access and CHIP Reauthorization Act of 2015.

Next Generation Accountable Care Organizations (NGACO) Model

On January 10, 2020, CMMI posted the second evaluation report of the NGACO Model currently being implemented in 41 ACOs across the country. Under this Model, NGACOs earn a share of savings from CMS for keeping Medicare spending for their beneficiary population below the benchmark and are required to pay a portion of the losses if spending exceeds those benchmarks. The report, which looks at the first two years of the NGACO Model (2016 and 2017) found small but statistically significant reductions in gross Medicare spending (-0.6 percent) and a non-significant increase in net Medicare spending (+0.4 percent) after accounting for CMS's risk-sharing payouts to participating NGACOs. The second evaluation report also found no statistically significant impact on acute care hospital spending or acute care hospital stays. The report is available here.

Primary Care First Payment Model Options

CMMI released an FAQ on its Primary Care First (PCF) payment model options, a set of voluntary payment options for advanced primary care practices to encourage delivery and coordination of advanced care through primary care physicians and practices. The PCF-General option is designed for primary care practices with advanced capabilities in exchange for flexibility and potential rewards based on performance. A separate PCF option focuses on seriously ill patients, with payments to reflect the high-need, high-risk nature of the population.

The PCF payment model options will be offered in the following 26 regions for a 2021 start date: Alaska (statewide), Arkansas (statewide), California (statewide), Colorado (statewide), Delaware (statewide), Florida (statewide), Greater Buffalo region (New York), Greater Kansas City region (Kansas and Missouri), Greater Philadelphia region (Pennsylvania), Hawaii (statewide), Louisiana (statewide), Maine (statewide), Massachusetts (statewide), Michigan (statewide), Montana (statewide), Nebraska (statewide), New Hampshire (statewide), New Jersey (statewide), North Dakota (statewide), North Hudson-Capital region (New York), Ohio and Northern Kentucky region (statewide in Ohio and partial state in Kentucky), Oklahoma (statewide), Oregon (statewide), Rhode Island (statewide), Tennessee (statewide), and Virginia (statewide).

Practice and payer selections will take place in Winter-Spring 2020, and the model will begin in January 2021. Applications for participation close on January 22, 2020. The FAQ is available here. Interested applicants can apply by registering on CMMI's application portal, which is available here.

Direct Contracting Model Options

CMMI opened applications for its Direct Contracting Model Options. As previously reported, the Direct Contracting Model is a set of voluntary payment models that aim to lower costs and maintain or improve quality for Medicare fee-for-service beneficiaries through risk-based contracts. There are currently two risk-sharing payment model options available for participation, which are the Professional Option and the Global Option. The Professional option is a lower-risk option with fifty percent shared savings/shared losses and a primary care capitation equal to seven percent of the performance year benchmark for enhanced primary care services. The Global Option is a full risk option with 100 percent shared savings/shared losses and either a primary care capitation or total care capitation. CMS plans to release more details on the third model, the Geographic option, at a later date.

The application to participate in the Direct Contracting Model Options closes on Tuesday, February 25, 2020. Information on Direct Contracting and the application process is available here.

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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