This summer, the Centers for Medicare & Medicaid Services (CMS), through its Innovation Center (CMMI), announced a new primary care model, Making Care Primary (MCP). CMMI is now accepting applications from eligible primary care practices through November 30.
This voluntary, 10.5-year, multi-payer model will run from July 2024 to December 2034, building on previous CMMI primary care models and features, currently for practices serving traditional Medicare (i.e., fee-for-service) beneficiaries. Practices eligible to participate must be Medicare-enrolled, be the “regular source” of primary care for at least 125 attributed Medicare beneficiaries, and have the majority of their primary care sites within one of the following states: Colorado, Massachusetts, Minnesota, New Mexico, New Jersey, upstate New York, North Carolina, and Washington. Current Primary Care First and ACO REACH participants are not eligible to participate.
Model Overview
MCP is intended to provide a pathway for primary care physicians with varying levels of experience in alternative payment models (APMs) and value-based care. This model is targeted to practices that have not previously participated in value-based care arrangements, including those that support underserved communities and are small, independent, or rural. The goal is to support these practices in the gradual adoption of population-based payments and in delivering advanced primary care.
CMMI has designed three MCP tracks for participants. Each track has a specific purpose with a specific intended practice type. For example, Track 1 is intended for primary care practices that have no experience in value-based care and lasts 2.5 years. During Track 1, participants are expected to build infrastructure to implement advanced primary care services, such as risk-stratifying their population, developing workflows for care management, chronic disease management, and behavioral health and healthcare-related social needs screenings. As participants progress through the tracks, there will be additional requirements for them to build upon activities to expand and integrate available services (Track 2) and to further optimize and expand care delivery and specialty integration (Track 3). While participants may apply for any of the three tracks, they will not be able to “move down” from a track or advance beyond Track 1 or Track 2 earlier than the end of the assigned track. All MCP tracks are expected to meet the criteria of being a MIPS APM, while Tracks 2 and 3 are expected to be classified as Advanced APMs (A-APMs).
Further, CMS will provide varying payments by track, with an upfront infrastructure payment available only to Track 1 participants. Transitioning to Tracks 2 and 3, participants will be moved into prospective primary care payments, while all tracks will include performance incentive payments and “investment” payments to support enhanced service delivery. In assessing MCP participants’ performance, CMS is emphasizing “whole-person care” by utilizing a specific MCP Performance Measure Set covering chronic conditions, wellness and prevention, behavioral health, person-centered care, and health equity. CMS will also measure the total per capita cost, emergency department utilization, and whether the participant is demonstrating continuous improvement year over year.
Should You Apply?
There have been limited opportunities for solo, small, and rural primary care practices to meaningfully participate in APMs. MCP presents an opportunity for many who have not previously had an opportunity to meaningfully participate in value-based care arrangements and should be strongly considered.
In particular, practices eligible for Track 1 will have the opportunity to receive two lump sum payments of $72,500, one at the start of the model and the second paid one year later. These funds can be used to increase staffing, develop and implement social determinants of health strategies (e.g., securing transportation services, housing-related services, home/environmental modifications, etc.), and to invest in health care infrastructure like certified electronic health record technology or expanding health IT systems. Given the financial challenges many primary care practices are facing today, the opportunity to receive such an investment is somewhat unique and could help to jumpstart necessary updates to improve overall care delivery.
Finally, participating in a MIPS APM (Track 1) or A-APM (Tracks 2 and 3), practices can move out of the normal MIPS reporting requirements and rigid payment structure. CMS has specifically designed this pathway to reduce reporting burdens and create new payment opportunities. Given the overarching burdens practices face with respect to MIPS reporting, this could be an additional benefit to practices, as the measure set will be more targeted and focused on the type of care family physicians provide.
Before You Decide
Interested practices should closely review the Request for Applications to determine eligibility and to identify the appropriate track. Practices should also closely monitor the MCP website for updates and information about the model and participation. Even if you are not eligible to participate at this stage, it is possible that CMS will expand the model to additional states to enable more practices to participate, so pay attention to these developments for the future.
In my view, this is a positive, albeit limited, development specifically intended for smaller family medicine practices. I hope that all ACOFP members will consider participating in this model and staying involved in efforts to protect and support primary care practices.
Further Information
More details on how and why to apply were provided at the Making Care Primary office hours, held on October 24, 2023.
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