Making Care Primary: A Run-Down on CMMI’s Newest Value Model

  • Health care and life sciences
  • 7/27/2023

Primary care is a lynchpin to patient wellness as well as a foundational element to value-based payment approaches. The newest primary care model -- Making Care Prim...

Primary care is a lynchpin to patient wellness as well as a foundational element to value-based payment approaches. The newest model in this area is called Making Care Primary (MCP).

The CMS Innovation Center (CMMI) recently announced that MCP would debut in 2024 in eight states: Colorado, Massachusetts, Minnesota, New Mexico, New Jersey, New York, North Carolina, and Washington.

We have answers to your top five MCP questions!

What is MCP?

MCP is focused on advancing primary, team-based, whole-person care. It is designed to meet primary care practices where they are at by offering three progressive tracks to begin transforming care and improving outcomes for their patients. In this way, the MCP Model will provide a pathway for primary care clinicians with varying levels of experience in value-based care to gradually adopt prospective, population-based payments while building infrastructure to improve behavioral health and specialty integration and drive equitable access to care. MCP is built upon previous primary care models (Comprehensive Primary Care, CPC+, and Primary Care First).

The model works to strengthen care management, care integration and community connections through coordination between patients’ primary care clinicians, specialists, social service providers, and behavioral health clinicians. It also includes a health equity lens. It is for Medicare providers and beneficiaries but looks to also algin with state Medicaid programs and other payers.

Who is eligible for the model?    

Eligible entities must:

  • Be a legal entity formed under applicable state, federal, or Tribal law authorized to conduct business in each state in which it operates.
  • Be Medicare-enrolled.
  • Bill for health services furnished to a minimum of 125 attributed Medicare beneficiaries. 
  • Have the majority (at least 51%) of their primary care sites (physical locations where care is delivered) located in an MCP state.

Important Note: Federally qualified health centers and Indian Health Services are eligible for this model.

However, rural health clinics, concierge-type practices (practices that collect a fee from patients for access to their services), current Primary Care First practices, current ACO REACH Participant Providers, and Grandfathered Tribal FQHCs are not eligible for MCP.

When does the model start?

The model begins July 1, 2024, and will run 10.5 years, through December 31, 2034.

What are the three model tracks?

The MCP has three model tracks designed for varying levels of experience with Medicare value-based payments.

  • Track 1 – Building Infrastructure. Track 1 is available to those who lack experience in Medicare value-based models. During Track 1, participants begin to develop the foundation for implementing advanced primary care services such as risk-stratifying their population, reviewing data, building out workflows, identifying staff for chronic disease management, and conducting health-related social needs screening and referral.
     
  • Track 2 – Implementing Advanced Primary Care. Track 2 continues to build on Track 1 fundamentals and expands out further to include partnerships with social service providers and specialists, implementing care management services, and systematically screening for behavioral health conditions.
     
  • Track 3 – Optimizing Care and Partnerships. Track 3 participants expand upon the requirements of Tracks 1 and 2 by using quality improvement frameworks to optimize and improve workflows, address silos to improve care integration, develop social services and specialty care partnerships, and deepen connections to community resources.

How do the financial payments work in these tracks?

There are six different payment mechanisms that vary depending on the model track.

  • Upfront Infrastructure Payment (Track 1 only). This is $145,000 to assist with building internal infrastructure. There are required uses for these dollars, such as increased staffing or technology/IT.  
  • Enhanced Services Payments (All Tracks). The participant’s aligned beneficiaries will be tiered into one of five categories with associated payments for each category. The tiering is based on HCC risk scores, area deprivation index scores and low-income subsidy status. These payment amounts are larger in earlier tracks and then gradually decrease over the track progression.
  • Performance Incentive Payments (All tracks). These payments are earned based on quality performance and total cost of care/utilization measures. The amount received varies by track and performance. Your ability to earn more PIP increases as you progress from track to track.
  • Prospective Primary Care Payment (Tracks 2,3). In the beginning years of the model (Track 1), participants continue to receive only fee-for-service (FFS) payments. As participants advance through the tracks, they transition to partial FFS and partial PPCP payments (PMPM capitation) and then to full PPCP (Track 3). Payments are made quarterly.
  • E-Consult Payments (Tracks 2,3). These payments are designed to encourage and reimburse MCP participants for utilizing e-consults related to patient care. Reimbursed at $40, geographically adjusted.
  • Ambulatory Co-Management Payment (Track 3). These payments are designed to reimburse specialists who collaborate with MCP participants on patient care. Reimbursed at $50 per month, geographically adjusted.

How CLA can help

Full model details are yet to be released, but we’re already assisting clients in analyzing MCP. Are you a primary care practice or FQHC thinking about the model but need more insight? CLA can help. Reach out today for details.

This blog contains general information and does not constitute the rendering of legal, accounting, investment, tax, or other professional services. Consult with your advisors regarding the applicability of this content to your specific circumstances.

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