Part I: What Providers want to know about CMS’ Comprehensive Primary Care+

The Centers for Medicaid and Medicare Services (CMS) held its CPC+ Announcement Event on Apr. 14 . Providers and other stakeholders flooded registration to learn about this historic new program, making it necessary for the agency to increase its webinar capacity and move its meeting location.

CMS anticipates a high volume of submissions for when the application period opens for providers on July 15. Each of the two tracks will be limited to 2,500 practices–roughly 20,000 providers, serving 25 million patients. CMS revealed that practice participation after this cap will be determined by lottery.

Practices currently participating in the existing CPC program, which expires at the end of the year, will not automatically be enrolled in CPC+.

CPC+ is a five-year initiative starting in Jan. 1, 2017 which looks to strengthen the nation’s primary care practices by injecting “greater cash flow and flexibility” for providers to pursue quality and delivery transformation. Physicians enrolled in CPC+ will receive monthly Medicare care management fees, performance-based incentive payments, and an improved reimbursement structure on two tracks.

“Track 1 practices will receive a care management fee that averages $15 per beneficiary per month. Track 1 is the most similar to the original CPC model, but CMS has refined the eligibility criteria, care delivery requirements and incentive payment opportunities to incorporate lessons learned in the original CPC model,” advises national health law firm Hall Render.

“Track 2 targets practices proficient in comprehensive primary care that are prepared to increase the depth, breadth and scope of medical care delivered to their patients, particularly those with complex needs. In support of this provision of care, payment is redesigned to be a hybrid of FFS paid at the time of the visit and FFS prospectively paid. Track 2 practices will also receive an enhanced care management fee averaging $28 per beneficiary per month to support care management, enhanced to support the more stringent requirements for Track 2 practices and to enable more comprehensive care for their patients with more complex needs.”

CPC+ timeline

CPC+ important dates to remember / source: CMS CPC+ Announcement Event, Apr. 14, 2016

CMS devoted approximately half of the Announcement Event to answering stakeholder questions. State of Reform attended the session and has captured several provider practice-related questions answered by CMS below.

Provider Questions:

Will [CMS] assign CPC practices to a track? Can current CPC practices be in track one?

Current CPC practices that are in good standing with CMS are eligible to apply to the model and can apply to the track to which they believe they are eligible. However, practices—including current CPC practices—that apply to track 2 that we find are not eligible will be offered an opportunity to apply to track one.

Does behavioral health integration have to currently exist at the practice to be eligible for track 2?

No, that’s one of the capabilities that we will build during the model.

What about overlap between state innovation models and CPC+? Can practices be in state innovation models and CPC+?

We expect that practices in regions where CPC+ occurs can be in both them and CPC+.

Is CPC+ limited to positions who accept Medicare or can practices like peds participate?

We do require that you have Medicare fee for service beneficiaries to be eligible for this model, but the practice population will likely consist of many patients covered by other payers participating in the model.

Assuming our region is chosen, in our practice we have 5% Medicare beneficiaries and 90% Medicaid beneficiaries, will we be eligible to apply?

This depends entirely on the participating Medicare payers. So, if your Medicaid beneficiaries are part of your state’s Medicaid fee for service and your state Medicaid agency is a payer partner, then the answer to that question is yes. Similarly, if those Medicaid beneficiaries are part of Medicaid managed care and those payers apply and are a part of the chosen region, then the answer to that remains yes, your practice can apply.

Can ACO participants apply?

Practices participating in a Medicare ACO are not eligible to simultaneously participate in CPC+.

Can multi-specialty practices with primary care participate?

Yes, only the primary care providers will be included in the model as participating practitioners.

Does CMS have an optimal practice size for participation?

We do have a minimum Medicare attributed beneficiary number which I believe is 150 beneficiaries. As long as practices have that, they are eligible. The model is designed to accommodate smaller practices of varying sizes.

Will practices that participate in CCM be eligible for CPC+?

Practices may build a chronic care management code for unattributed beneficiaries, but for beneficiaries that are attributed to CPC+, they are not permitted to bill the CCM. And this is due to the overlap in services of the CCM and care management fee.

Can you participate in CPC+ if you are already an MSSP ACO provider?

You cannot be in both the MSSP and CPC+ at the same time. So, the answer to that question is you can apply, but you cannot be in both at the same time.

Do you anticipate that the seven CPC regions will be included?

It depends entirely on payer interest, but we would be quite pleased to include the seven existing CPC regions.

How do I know if my city will be one of the participating sites?

We will announce the regions that will be involved in CPC+ right before the practice application period opens, and we will broadcast that as widely as possible. And of course, include that information on our website.

Will participation in CPC+ make physicians eligible for MACRA?

Further MACRA regulations will be a proposed rule making coming up shortly, so we encourage people to keep a look out for that. For now, it is not determined.

Will track 2 qualify to be an eligible alternative payment model?

The MACRA public notice of rulemaking will be coming out shortly, we expect. We hope to find out further answers of whether practices participating in CPC+ will be eligible alternative payment models once that rule comes out.

Is it envisioned that all track 1 practices will move to track 2 by 2019?

No, track 1 practices will stay in track 1 for the full five years of the model.

Will patients be attributed to mid-level NP and PA providers or only MDs and DOs?

Yes, they will be attributed to any primary care practitioner which is defined as an MD, DO, NP, or PA or clinical nurse specialist who has a primary care designation of family medicine, internal medicine, or geriatric medicine.

There were still quite a few questions left as time ran out on this informational session. CMS will be holding a second informational session on Apr. 19 to accommodate additional questions.

Read on to Part II: Answers to payer questions about Comprehensive Primary Care +.