On June 8, 2023, the Centers for Medicare & Medicaid Services (“CMS”) announced a new Center for Medicare and Medicaid Innovation (“the Innovation Center”) model focused on improving access to primary care and advancing care management and care coordination.

The Making Care Primary (“MCP”) Model is a 10.5-year multi-payer model, which includes a progressive three-track approach based on participants’ experience level with value-based care and alternative payment models. CMS will provide financial support for MCP Model participants in Track One to focus on building infrastructure to support care transformation. In Tracks Two and Three, CMS will include certain advance payments and offer more opportunities for bonus payments based on participant performance. Participants of the MCP Model will include Federally Qualified Health Centers (“FQHCs”), Indian Health Service facilities, and Tribal clinics, among other organizations. The MCP Model will launch in eight states—Colorado, Massachusetts, Minnesota, New Mexico, New Jersey, New York, North Carolina, and Washington—in July 2024.  

CMS states that the goals of MCP 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. CMS also states that the MCP Model will equip primary care clinicians with tools to form partnerships with health care specialists and to leverage community-based connections to address patients’ health needs as well as their health-related social needs (“HRSNs”).

Overview of the MCP Model

CMS has stated that primary care clinicians serve as frontline health care professionals by providing preventive services and helping to manage chronic conditions. While primary care clinicians also facilitate care coordination with other clinicians, care coordination has become increasingly challenging as patients see a greater number of specialists more frequently. The MCP Model would address this issue by increasing the investment in primary care so patients can access more whole-person care.

According to CMS, the MCP Model would build infrastructure to improve behavioral health and specialty integration and drive equitable access to care while providing a pathway for primary care clinicians (with varying levels of experience in value-based care) to gradually adopt prospective, population-based payments. The MCP Model takes a progressive, three-track approach designed to recognize participants’ varying experience in value-based care and to give participating organizations flexibility. The MCP Model will include prospective payments for primary care that will reduce participants’ reliance on fee-for-service (“FFS”) payments. The MCP Model will allow participants to expand care management, screen for HRSNs, and integrate with specialty care by providing risk-adjusted enhanced services payments, which will also be paid prospectively and represent an additional investment in primary care.

The MCP Model includes the following three tracks:

• Track 1 will be available to organizations that do not have experience in value-based care in order to allow them time to build capabilities, while continuing to bill FFS and receiving additional financial support from CMS. Track 1 allows participants to develop the foundation for implementing advanced primary care services. CMS will provide additional financial support to help participants develop care transformation infrastructure and build advanced care delivery capabilities (e.g., risk-stratifying their population, reviewing data, building out workflows, identifying staff for chronic disease management, and conducting HRSNs screening and referral). Participants can begin earning financial rewards for improving patient health outcomes in this track.
• Track 2 will shift participants’ revenue to a partial prospective primary care payment and will require performance assessment on clinical and utilization/cost metrics. Track 2 allows participants to partner with social service providers and specialists, implement care management services, and systematically screen for behavioral health conditions. Payment for primary care will shift to a 50/50 blend of prospective, population-based payments and FFS payments. As participants continue to build advanced care delivery capabilities, CMS will continue to provide additional financial support at a lower level than Track 1. Participants will be able to earn increased financial rewards for improving patient health outcomes.
• Track 3 will shift participants to full prospective primary care payment with larger bonus opportunity. Track 3 enables participants to 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. While payment for primary care will shift to fully prospective, population-based payment, CMS will continue to provide additional financial support (at a lower level than Track 2) to sustain care delivery activities. In addition, participants will have the opportunity to earn greater financial rewards for improving patient health outcomes.

To be eligible to apply for participation in the MCP Model, an organization must be Medicare-enrolled; bill for health services furnished to a minimum of 125 attributed Medicare beneficiaries; and have the majority (at least 51%) of their primary care sites (physical locations where care is delivered) located in an MCP state.

Takeaways

CMS is hosting a webinar on the MCP Model on June 27 (register here). CMS plans to release a Request for Applications (“RFA”) for the MCP Model, which will provide additional technical details and information about state-specific eligibility criteria. CMS will begin accepting applications for the MCP Model in late summer 2023. The MCP Model will launch on July 1, 2024. Organizations interested in applying for the MCP Model should attend the webinar and continue to monitor the release of the RFA and other updates from CMS.

As outlined in a previous Crowell Health Solutions’ blog, the MCP Model aligns with the Innovation Center’s strategic objectives to address health equity and drive accountable care, which were outlined in an updated Innovation Center Strategy Refresh. The MCP Model includes several components designed to improve health equity, including requirements for participants to develop a strategic plan for how they will identify and reduce disparities and payment adjustments based on clinical indicators and social risk. Moreover, it demonstrates CMS’ continued interest to advance health equity and population health by addressing HRSNs. The MCP model requires participants to implement HRSN screening and referrals and states that CMS will measure the percentage of patients screened for HRSNs. For more information on how the MCP Model could impact your organization, please contact the professionals listed below, or your regular Crowell Health Solutions contact.