CMS Announces Final Organizations for the Global and Professional Direct Contracting Model, Halts Additional Applications and Future Solicitations

Sheppard Mullin Richter & Hampton LLP

On Thursday, April 8, 2021, the Center for Medicare and Medicaid Innovation (the “Innovation Center”) announced its final list of 53 organizations set to participate in the Global and Professional Direct Contracting (“GPDC”) Model (previously named the Direct Contracting Model for Global and Professional Options). The 53 Direct Contracting Entities (“DCEs”) are participating in the first Performance Year (“PY2021”) of the GPDC Model, which runs from April 1, 2021 through December 31, 2021. The DCEs will serve Medicare fee-for-service (“FFS”) beneficiaries in 38 states as well as in the District of Columbia and Puerto Rico.

The Innovation Center announced it will not be accepting new applications for any of the GPDC Model participant types, including for Medicaid Managed Care Organization-based DCEs. The Innovation Center also announced it will not solicit applications for a second round of participants to start the GPDC Model on January 1, 2022. However, organizations that applied in the previous application cycles—either for the Implementation Period or for PY2021—and that deferred their start date to January 1, 2022 will be permitted to start the GPDC Model as planned on January 1, 2022, as long as they continue to meet GPDC Model requirements.

The GDPC Model is a set of two voluntary risk-sharing options aimed at reducing expenditures and preserving or enhancing quality of care for beneficiaries in Medicare FFS, also known as Original Medicare. The GDPC Model aims to build upon lessons learned from prior innovation models and private sector risk-sharing arrangements and to test the next evolution of risk-sharing arrangements to produce value and high-quality health care. The risk-sharing options are expected to reduce burden, support a focus on beneficiaries with complex, chronic conditions, and encourage participation from organizations that have not typically participated in Medicare FFS or Innovation Center Models.

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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