On June 8, 2023, the Centers for Medicare and Medicaid Services (CMS) announced a new advanced primary care payment model in eight states that will begin accepting applications this summer. Dubbed the Making Care Primary (MCP) Model, the model will be open to primary care providers with limited or no value-based care experience, including:
- Federally Qualified Health Centers (FQHCs)
- Indian Health Services facilities
- Tribal clinics
- Rural and underserved primary care clinics
The model will operate for 10 1/2 years beginning on July 1, 2024, in the following eight states:
- Colorado
- Massachusetts
- Minnesota
- New Jersey
- New Mexico
- New York
- North Carolina
- Washington
Model Goal
Like other models tested by the Center for Medicare and Medicaid Innovation (CMMI), the goal is to reduce disparities in care and improve patient outcomes.
This model will help CMMI achieve its goal to have 100% of traditional Medicare beneficiaries and most Medicaid beneficiaries in accountable care arrangements by 2030.
CMS is working with the Medicaid agencies in each state and plans to engage commercial payors in the coming months to support care transformation across multiple payors. Commercial payors are encouraged to partner with CMS.
MCP participants will improve care delivery through a focus on three domains:
- Care management of the chronically ill to reduce unnecessary emergency department usage and reduce the total cost of care
- Care integration with specialty care clinicians to improve coordination while using evidence-based behavioral health screening and evaluation
- Community connection and partnership with community services to address health-related social needs
Eligibility Criteria
The requirements for an organization to participate in an MCP, according to CMS, are:
- Legal entity formed under applicable state, federal, or Tribal law authorized to conduct business in each state in which it operates
- Medicare enrollment
- Billing for services to a minimum of 125 attributed Medicare beneficiaries
- At least 51% of primary care sites in an MCP state
Rural Health Clinics, concierge practices, current Primary Care First (PCF) practices, current Accountable Care Organization (ACO) Realizing Equity, Access, and Community Health (REACH) participant providers, and legacy Tribal FQHCs aren’t eligible for MCP.
After the model has been in place for six months, organizations won’t be able to participate in the Medicare Shared Savings Program and MCP at the same time.
Payments
MCP is a three-track model with the first track reserved for organizations with no prior value-based care experience.
Track One: Building Infrastructure
- Payments will continue to be fee-for-service (FFS)
- CMS will provide advanced payments to invest in infrastructure
- Participants can earn performance-based payments for improving patient health outcomes
Track Two: Implementing Advanced Primary Care
- Payments will transition to equal portions of FFS and prospective, population-based payments
- CMS will provide advanced payments to invest in infrastructure, but less than Track One
- Participants can earn performance-based payments for improving patient health outcomes, more so than in Track One
Track Three: Optimizing Care and Partnerships
- Payments will transition to fully prospective, population-based payments
- CMS will provide advanced payments to sustain care delivery activities, but less than Track Two
- Participants can earn performance-based payments for improving patient health outcomes, more so than in Track Two
More technical details, including the financial methodology, will be released with the Request for Applications, later this summer. Information about the Medicaid payment methodologies will be provided by each respective State Medicaid agency.
We’re Here to Help
Moss Adams has extensive experience helping primary care providers evaluate and thrive in alternative payment models. We can help you determine whether MCP makes financial sense for your clinic, oversee the application process, and support your program planning and implementation for success with the model. To learn more, contact your Moss Adams professional.