America’s Physician Groups (APG), the Los Angeles-based association of accountable physician groups, representing over 300 medical groups nationwide, on Oct. 24 praised the Request for Application (RFA) released on that date by the Centers for Medicare & Medicaid Services (CMS), through its Center for Medicare & Medicaid Innovation (CMMI).
As APG’s press release stated, “The Centers for Medicare & Medicaid Services (CMS) released today a Request for Application (RFA) for the Centers for Medicare & Medicaid Innovation (CMMI) Primary Care First Model, a new alternative payment model that offers an innovative payment structure to support the delivery of advanced primary care. Primary Care First Model Options will be offered in 26 regions with a January 2021 start date.”
And it quoted Don Crane, APG’s president and CEO, as saying, “We’re very excited to see the start of this new model and commend CMMI for their work in helping advance the value movement. Our Federal Affairs team is digesting today’s RFA and we look forward to educating our members and others on how this new model may impact the patients and communities serve.”
As the APG press release noted, “Some key highlights from the Primary Care First Model:
The model includes six performance years with two cohorts of participating practices (one cohort in 2021; the other in 2022)
The majority of professional revenue is prospective population-based payment
Since this is a multi-payer model, payers will separately have an option to submit a non-binding statement of interest, indicating a willingness to potentially partner with both CMS and other participants
Neither NextGen ACOs nor CPC+ are currently eligible to participate in the model
Applications are not legally binding
The RFA application period opens today [Oct. 24] and ends January 22, 2020. Applicants must register first in order to access the application portal. CMS will also accept Primary Care First applications from individual primary care practice sites that meet eligibility requirements.”
As CMS explained in its announcement on Oct. 24:
“This Request for Applications (RFA) introduces Primary Care First, a new alternative payment model that offers an innovative payment structure to support the delivery of advanced primary care. Primary Care First is based on many of the same underlying principles as Comprehensive Primary Care Plus (CPC+), an existing Center for Medicare and Medicaid Innovation (CMMI) primary care model. CPC+ is designed to accommodate primary care practices at different stages of readiness to assume accountability for patient outcomes and currently has two tracks with different levels of payment redesign and care delivery requirements. By comparison, Primary Care First is geared towards advanced primary care practices that are ready to accept financial risk in exchange for greater flexibility, increased transparency, and performance-based payments that reward participants for outcomes. Additionally, in Primary Care First, CMS will provide payments that are higher than historical Medicare fee-for-service (FFS) payments, in the aggregate, for participating practices that care for complex, chronically ill patients, and will enable participating practices to proactively engage seriously ill patients who exhibit fragmented care patterns. Primary Care First will be tested over six performance years, with two staggered cohorts of participating practices, each participating for five performance years—one cohort will participate in the model from 2021 through 2025 and a second will participate from 2022 through 2026. Participating practices will generally include primary care practitioners, as well as other clinicians that are managing high need, seriously ill populations. Primary Care First tests several new concepts:
• Shifting focus to outcomes. Practices will be accountable for their attributed patient population through a simple two-tiered payment structure: (1) a total primary care payment, which consists of a population-based payment and flat primary care visit fee that allows care to be driven by clinicians rather than administrative requirements and revenue cycle management; and (2) a performance-based adjustment with greater upside than downside potential tied to a clear outcome measure—acute hospital utilization—that is highly correlated with total cost of care.
• Increasing reimbursement for practices that care for patients with complex, chronic needs, relative to practices’ historical aggregate Medicare FFS revenue. Practices that serve complex, chronic patient populations will receive a larger population-based payment for the Medicare covered services provided to this population. In aggregate, combined with the flat primary care visit fee revenue, these practices’ payments under the model will be larger than the Medicare FFS reimbursement they have historically received for delivering primary care services to complex chronic patients. The larger population-based payment is intended to account for the higher disease burden in these populations and the increased resources required to serve patients with multiple chronic illnesses.
• Supporting high need, seriously ill populations. In addition to providing higher payments for practices serving complex, chronic patient populations, Primary Care First also enables primary care practices, including clinicians who are enrolled in Medicare and typically provide hospice or palliative care services, to take responsibility for the care of high need, seriously ill beneficiaries who currently exhibit a fragmented pattern of care – a group referred to under the model as the Seriously Ill Population or “SIP.” CMS’ goal is to identify seriously ill beneficiaries whose care does not appear to be well managed, and then provide additional financial resources for participating practices to proactively engage these beneficiaries, address their intensive care needs through comprehensive and person-centered care, help them achieve clinical stabilization, and then facilitate a relationship between the beneficiary and a practitioner who will manage the beneficiary’s longer term care after they transition out of the SIP component of the model.
