CMS Solicits Payer Participation to Next Phase of CPC+

February 23, 2017 - In support of second round of payer solicitation for Comprehensive Primary Care Plus (CPC+), The Centers for Medicare & Medicaid Services (CMS) has issued a list of frequently asked questions aimed at increasing payer support for the alternative payment model (APM).

Eligible clinicians in the Quality Payment Program can avoid negative Medicare payment adjustment and potentially receive positive financial rewards for participating in an advanced APM, of which CPC+ is one.

The most recent payer solicitation for CPC+ Round 2 focuses on ensuring payer support of this advanced APM in its next iteration. Payers have until 5PM ET on April 3 to submit proposals to partner in CPC+.

In the FAQ, the federal agency highlighted multiple benefits for payers, both private and public, considering submitting proposals to partake in CPC+2. These value propositions include allowing dual participation in CPC+ and the Medicaid Shared Savings Program, flexible requirements on risk-based payments, and facilitated transition towards CPC+ alignment.

As part of MACRA implementation, CMS created the Quality Payment Program to transition providers and payers to value-based care and reimbursement. For CPC+ to be effective, CMS is calling on more payers to participate, with flexible requirements for doing so.

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If a payer is in a healthcare region where primary care practices are participating in Medicare accountable care organizations (ACOs), then the payer can support these practices through CPC+, which allows dual participation for practices to be supported by Shared Savings ACOs and CPC+.

The payment flows for dual-participation are generally flexible, but in this case a primary care practice will forgo the CPC+ performance-based incentive payment and instead be subject to the ACO’s shared savings or losses. Practices in dual-participation will have to use CPC+ care delivery models while adhering to an ACO’s reporting and care processes.

“All primary care practices that are participating in CPC+ will be required to implement the CPC+ care delivery model and adhere to the ACO’s required care processes,” CMS said. “Participating practices that are also participating in an ACO must also adhere to quality reporting requirements for both CPC+ and the Shared Savings Program.”

Payers in states that prohibit non-HMO plans from offering risk-based payments are still eligible to participate in CPC+. CMS allows payers to adopt partial population-based payments without downside risk, full population-based payments without downside risk, and episodic payment.

“Whether a payer can offer a capitated or risk-based arrangement will depend on the laws and regulations in place in your state. In states with regulations that prohibit capitated or risk-based payments, we encourage payers to consider alternate arrangements that will support flexibility in the delivery of primary care,” the federal agency stated.

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As part of payer alignment, CMS asks that payers to task practices with pursuing the goals and initiatives similar to those of CPC+ participants.  CMS does not require payers to establish identical methods on key payment, quality, and data sharing elements with other payers.

“By alignment, CMS means that, for each payer in the model, these elements need not be identical but should be oriented so that the practice incentives and goals are consistent across all payers partnering in the model,” it explained. “CMS also wants to ensure that the model allows for sufficient flexibility for payers to implement approaches that are aligned with the needs of their members and/or beneficiaries.”

CMS will accept 2,600 practices in CPC+ Round 2 until the deadline of April 3rd, 2017, and already selected 2,893 practices in CPC+ Round 1 for a maximum of 5,500 practices across both rounds. This is the latest effort from CMS to drum up payer support of this advanced APM after experiencing positive payer participation and patient outcomes from the first CPC.

CMS hopes that a sufficient number of payers will enable provider access to advanced APMs by the years 2018 through 2022. CPC+ already serves 1.76 million Medicare beneficiaries, supports 2.983 primary care providers, and includes 13,090 physicians.

“Further, CPC+ is built on lessons learned from the Comprehensive Primary Care (CPC) initiative, and results from the first three years of CPC are promising,” CMS said.  

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“Overall, the CPC initiative results indicate improvements in patient experience and care quality, and a reduction in total cost of care over the first two years of the initiative offsetting a substantial portion of care management fees paid by CMS. Payer partners may also see significant changes in quality and cost of care by investing in primary care reform.”

In late spring and early summer of 2017, payers will receive notification from CMS regarding the status of their proposals. Those approved to participate will receive a Memorandum of Understanding. The federal agency will announce additional selected regions around the same time and prior to primary care practices applying to participate in CPC+ Round 2.