CMS Announces Multi-State Initiative to Support Primary Care Practices with Varying Levels of Value-based Care Experience
Making Care Primary Model Overview
On June 8th, CMS announced the upcoming launch of the Making Care Primary (MCP) model. This new CMS model aims to achieve three goals:
- Provide patients with primary care services that are integrated and coordinated with specialty care as well as leverage community-based connections to better address patients’ social determinants of health (SDOH) needs
- Create another opportunity for primary care organizations to participate in value-based care (VBC) arrangements
- Enhance the quality of care and health outcomes while better managing total beneficiary spend
This most recent VBC payment and delivery model focuses on strengthening primary care infrastructure, particularly for smaller primary care and safety net organizations. Historically, these organizations have had lower rates of participation in Medicare Alternative Payment Model (APM) programs.
“This model focuses on improving care management and care coordination, equipping primary care clinicians with tools to form partnerships with healthcare specialists, and partnering with community-based organizations.” – CMS Administrator, Chiquita Brooks-LaSure
The MCP model offers three tracks that build on one another: Building Infrastructure (Track 1), Implementing Advanced Primary Care (Track 2), and Optimizing Care and Partnerships (Track 3).
| MCP Track | Track Design Goals | Payment Model |
|---|---|---|
| Track 1: Building Infrastructure | Develop a foundation for implementing advanced primary care services which include:
|
100% Fee-for-service (FFS):
|
| Track 2: Implementing Advanced Primary Care |
|
50% FFS and 50% prospective population-based payments:
|
| Track 3: Optimizing Care and Partnerships |
|
100% prospective population-based payments:
|
This new model builds on one of Centers for Medicare & Medicaid Innovation’s (CMMI’s) core areas of focus which is advancing health equity. The MCP model includes several components designed to make healthcare more equitable and accessible to Medicare and Medicaid beneficiaries. These include integrating clinical indicators and social risk factors into payment calculations, requiring participants to create a health equity strategic plan which includes HRSN screening and data tracking, and helping eligible patients with cost-sharing.
MCP Program Timeline and Eligibility
CMS is offering this model in eight states initially with the possibility for expansion given the program’s stated timeline of 10.5 years (July 1, 2024, to December 31, 2034). Participants must reside in these eight states:
- Colorado
- Minnesota
- New Mexico
- North Carolina
- Massachusetts
- New Jersey
- New York
- Washington
CMS has stated that these states were initially chosen based on several criteria, including an ability to align with the state Medicaid agencies.
- Legal entity recognized by the state
- Medicare enrolled entity
- Have at least 125 attributable Medicare beneficiaries
- Have at least 51% of primary care sites within an MCP state
Notable exclusionary criteria for entities not eligible to participate in MCP:
- May not concurrently participate in Medicare Shared Savings Program (MSSP) after the first six months of the model
- May not be current ACO REACH Participant Providers or current Primary Care First (PCF) practices
- Grandfathered Tribal Federally Qualified Health Centers, Rural Health clinics, and concierge practices are also not eligible
CMS plans to release more details in the coming weeks. Request for Applications (RFA) and commencement of the application period for this model is expected later this summer.
Observations About MCP Program and What It Signals
The MCP model is a shift for CMS from focusing on more advanced two-sided (e.g., risk sharing) models such as ACO REACH and Enhancing Oncology Model. This gives organizations without significant VBC experience an opportunity to join a CMS program that matches their current readiness and provides resources to build the necessary capabilities over time. Practically speaking, models with broader appeal and flexibility improve CMS’ ability to reach its stated goal of having every Medicare beneficiary and most Medicaid beneficiaries in an alternative payment model (APM) by 2030.
Launching the MCP model further reinforces the role of primary care in driving VBC. Primary care is the most direct mechanism for getting traditional Medicare beneficiaries in an APM, and in many ways it has the strongest ability to consistently impact outcomes and cost at a broader level. CMS hopes to support primary care providers by aligning with state Medicaid agencies to bring more scale and alignment to participating providers.
“The Making Care Primary Model represents an unprecedented investment in our nation’s primary care network and brings us closer to our goal of reaching 100% of traditional Medicare beneficiaries and the vast majority of Medicaid beneficiaries in accountable care arrangements, including advanced primary care, by 2030… With the introduction of this new model, CMS reinforces its view that primary care providers are the first line of defense for prevention, screening, management of chronic conditions, and overall wellness.” – CMS Innovation Director Liz Fowler
Key Questions for Consideration
- If your organization—or a related organization—meets the eligibility requirements for MCP, how might it fit with your long-term VBC strategy? How does it fit with your Medicare/Medicaid strategy and approach?
- Does MCP provide a credible “onramp” for affiliated primary care providers to build the resources and gain experience with VBC care models?
- Even if your organization doesn’t reside in a state eligible for MCP participation, what components of MCP highlight gaps for evolving the organization’s VBC capabilities and population health management skills? For example, does your care management approach include relationships with community organizations to address HRSN of your participants?
- Transitioning towards VBC takes time and intentionality, and organizations at every stage of the journey and in all markets can expect continued opportunities for reinforcing care models that emphasize care coordination and health equity as CMS and other payers explore innovative payment models. Has your organization clearly articulated its approach and priorities for addressing the care model, organizational and financial implications of VBC?
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The value-based care experts at Sg2 are equipped to provide your organization with unique insights and impactful recommendations to work through any questions you have, and more. Please reach out to us to speak with an Sg2 value-based care expert.
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Michael Koch Consulting Director
As a member of the Value-Based Care team, Michael brings extensive knowledge around Medicare and Medicaid accountable care organization (ACO) models and their associated quality programs.Email: mkoch@sg2.com