Global and Professional Options Direct Contracting Model RFA and LOI Now Active

Sheppard Mullin Richter & Hampton LLP

Sheppard Mullin Richter & Hampton LLP

On April 21, 2019, the Center for Medicare and Medicaid Innovation (“CMMI”) announced the CMS Primary Cares Initiative – a voluntary, risk-based initiative to transform the Medicare program’s reimbursement of primary care services from a fee-for-service payment system to a value-based system that rewards physicians who keep patients healthy and out of the hospital. The CMS Primary Cares Initiative creates five payment models under two paths: the Primary Care First Model (“PCF Model”) and the Direct Contracting Model (“DC Model”). All five models focus on care for chronically and seriously ill patients.

This past Monday, November 25, 2019, CMMI announced its release of the Request for Application (“RFA”) and Letter of Intent (“LOI”) to be submitted by those primary care providers applying for participation in two DC Model options: the Global Option and the Professional Option – both options slated to begin in 2021. A third DC Model option – the Geographic Option – is not covered by Monday’s issuance. In a prior announcement dated October 24, 2019, CMS released a separate RFA for both of the PCF Model options, which are also set to begin in 2021.

Although parties interested in participating in the Global and Professional options were originally required to submit a nonbinding LOI last August, CMMI has reopened the submission period for those who did not meet the August deadline. Interested parties now have until December 10th to submit an LOI.

There will be two application submission periods for the Global and Professional options: (i) a submission period for applicants interested in participating in the DC Model’s “Implementation Period” – a period during 2020 in which “Direct Contracting Entities” will engage in beneficiary alignment activities (consistent with the DC Model’s emphasis on voluntary alignment), care coordination, and care management; and (ii) a submission period for those applicants that wish to forego the Implementation Period and start the model in the first of five performance years (“PYs”) – PY2021 to PY2025. The application period for participation in the Implementation Period opened on November 25th and will extend until February 24, 2020. The application period for those that wish to participate in the first PY will commence in spring 2020.

The application tool for Implementation Period applicants will become available in December 2019.

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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