CMS Initiative to Enhance Primary Care Services

On June 8, the Centers for Medicare & Medicaid Services (CMS) announced a new primary care model – the Making Care Primary (MCP) Model – that will be tested under the Center for Medicare and Medicaid Innovation in eight states.[i]  The eight states are Colorado, Massachusetts, Minnesota, New Jersey, New Mexico, New York, North Carolina, and Washington.[ii]  The model will launch on July 1, 2024, and will run for 10.5 years, until December 31, 2034.[iii]  Primary care organizations within participating states may apply when the application opens in late summer 2023.[iv] 

The model will build upon previous primary care models, “such as the Comprehensive Primary Care (CPC), CPC+, Primary Care First models, and the Maryland Primary Care Program (MDPCP).”[v]  The MCP Model will help participants gain additional revenue to build infrastructure, expand the accessibility of primary care services, and improve coordination with specialists.[vi]  CMS Administrator Chiquita Brooks-LaSure stated, “[t]he goal of the Making Care Primary Model is to improve care for people with Medicaid and Medicare.”[vii]  The MCP model’s three main goals are to “(1) ensure patients receive primary care that is integrated, coordinated, person-centered and accountable; (2) create a pathway for primary care organizations and practices – especially small, independent, rural, and safety net organizations – to enter into value-based care arrangements; and (3) to improve the quality of care and health outcomes of patients while reducing program expenditures.”[viii] 

The MCP Model seeks to improve care for patients by expanding and enhancing care management and care coordination, equipping primary care clinicians with necessary tools to foster relationships with health care specialists, and addressing patients’ health and health-related social needs by leveraging community connections.[ix]  The MCP Model has built-in flexibility that will allow CMS to work with participants to address any community-specific priorities, such as “care management for chronic conditions, behavioral health services, and health care access for rural residents.”[x]  The MCP Model is also expected to create savings downstream over time by fostering improved preventive care and reducing possible avoidable costs, like repeat hospitalizations.[xi]  Finally, the MCP Model will allow CMS to continue to work to decrease disparities in care and push for better experiences and outcomes for patients.[xii]

To be eligible to apply to participate in MCP, an organization 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 percent) of their primary care sites (physical locations where care is delivered) located in an MCP state. [xiii] 

The MCP Model excludes certain organizations from eligibility.[xiv]  Non-eligible organizations are “[t]he Rural Health Clinics, concierge practices (practices that collect a fee from patients for access to their services), current Primary Care First (PCF) practices, current ACO REACH Participant Providers, and Grandfathered Tribal FQHCs.”[xv]  Additionally, for the first six months of the MCP Model, organizations are prohibited from concurrently participating in the Medicare Shared Savings Program and the MCP.[xvi]   

The MCP Model includes an innovative three-track approach that accounts for participants’ experience “with value-based care and alternative payment models,”[xvii] including reserving one track “for organizations with no prior value-based experience.”[xviii]  One of the purposes behind the three-track model is to give organizations flexibility by “allowing them to choose their participation track and receive payments that reflect each participant’s experience towards accountable care.”[xix]  In all three tracks, participants will receive some level of enhanced payments.[xx]  The three-track model meets participants where they are in their readiness and allows for an easier transition to value-based care, which allows CMS to further its goal of “[ensuring] 100 percent of traditional Medicare beneficiaries are in a care relationship with accountability for quality and total cost of care.”[xxi]  Below is a brief overview of each of the tracks:

• Track 1 – Building Infrastructure: This track allows participants to develop the foundation necessary to implement advanced primary care services.  These foundational steps include, “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 1 provides organizations with some financial help as “payment for primary care will remain fee-for-service (FFS), while CMS provides additional financial support to help participants develop care transformation infrastructure and build advanced care delivery capabilities.”  Participants can also earn “financial rewards for improving patient health outcomes in this track.” [xxii] 
• Track 2 – Implementing Advanced Primary Care: As participants progress to Track 2, they will continue to build on the work done in Track 1 by “partnering with social service providers and specialists, implementing care management services, and systematically screening for behavioral health conditions.”  Unlike Track 1, payment for primary care shifts to a 50/50 combination of “prospective, population-based payments and FFS payments.”  Under Track 2, CMS will continue to provide additional financial support but its support will be lower than at Track 1.  Additionally, like Track 1, participants can earn financial rewards for improving patient health outcomes.[xxiii]
• Track 3 – Optimizing Care and Partnerships: Building on the requirements of Tracks 1 and 2, in Track 3, participants will use “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.”  Unlike the first two tracks, Track 3 requires participants to shift to a “fully prospective, population-based payment.”  Like the previous two tracks, CMS will provide financial support at a lower level than Track 2, and participants will continue to have the ability to earn financial rewards by improving patient health outcomes.[xxiv] 

CMS will release a Request for Applications (RFA).[xxv]  CMS plans to commence the application period for this model later this summer and will release more information on the model’s design in the near future.[xxvi]  To apply for the MCP, please submit a non-binding Letter of Intent here.  For the most up-to-date information on the MCP, please visit CMS’s website here.

[i] Making Care Primary (MCP) Model, Centers for Medicare & Medicaid Services (last updated July 5, 2023).

[ii] Id.

[iii] Id.

[iv] Id.

[v] Id.

[vi] CMS Announces Multi-State Initiative to Strengthen Primary Care, Centers for Medicare & Medicaid Services, (June 8, 2023).

[vii] CMS Announces Multi-State Initiative to Strengthen Primary Care, supra note 6.

[viii] Id.

[ix] Making Care Primary (MCP) Model, supra note 1.

[x] CMS Announces Multi-State Initiative to Strengthen Primary Care, supra note 6.

[xi] Id.

[xii] Id.

[xiii] Making Care Primary (MCP) Model, supra note 1.

[xiv] Id.

[xv] Id.

[xvi] Id.

[xvii] CMS Announces Multi-State Initiative to Strengthen Primary Care, supra note 6.

[xviii] Making Care Primary (MCP) Model, supra note 1.

[xix] Id.

[xx] Id.

[xxi] CMS Announces Multi-State Initiative to Strengthen Primary Care, supra note 6.

[xxii] Making Care Primary (MCP) Model, supra note 1.

[xxiii] Id.

[xxiv] Id.

[xxv] Id.

[xxvi] Id.