Amid growing consensus that MACRA may delay from its 2017 performance year start, CMS is moving ahead with next year’s launch of the Comprehensive Primary Care Plus (CPC+) program.
Fourteen multi-payer regions and all participating payers were announced August 1, (listed below) and practices can now begin applying through September 15. CMS has launched an application portal for practices.
CPC+ is part of MACRA, as one of six Advanced Alternative Payment Models, but certainly can be undertaken on its own. CMS has a deadline of November 1 to produce a MACRA final rule, but can announce MACRA’s fate anytime prior.
Also newsworthy within CPC+ is CMS’ recent announcement that primary care practices can participate in a CMS MSSP ACO and the CPC+ program at the same time.
Offering Track 1 and Track 2 risk levels, practices applying for Track 2 must include a vendor letter of support with the application, or your vendor can submit a global letter of support to cut down on the practice paperwork.
CMS had wanted to reach its goal of 20 payer regions, but has settled for 14 to keep the program on its timeline. Next to be seen is whether the agency’s goal of attracting 20,000 docs from 5,000 practices will be met. Born out of CMS’ earlier CPCI program, results have been mixed based on this examination from Mathematica Policy Research.
Dual eligibility and payments
Essentially, primary care providers in a CMS MSSP ACO, Tracks 1, 2 or 3, can also participate in CPC+.
Financially, payments can come from both programs, the care management fee only from CPC+, combined with the shared savings incentive payment from the MSSP. (Overall, CPC+ offers a performance-based incentive payment and a care management fee based on Track, for those not participating in an MSSP.)
And of course, there is some fine print.
Overall, beneficiary attribution won’t change in either program. In CPC+, Medicare beneficiaries are aligned prospectively and quarterly, and in MSSP, alignment is annual, so it is possible that some beneficiaries will be attributed to a CPC+ practice but not the ACO that includes that CPC+ practice, or attributed to an ACO but not attributed to a CPC+ practice within that ACO.
CMS has stated it will communicate this process individually with participating practices, and that it reserves the right to counsel applying practices on which CPC+ Track is the best fit.
New risk scoring and HCC code updates
For the CPC+ program, CMS has embarked on a new risk adjustment model for 2017, with the risk adjusted payment based on updated Hierarchical Condition Category (HCC) risk scores.
The new model has separate coefficients for partial benefit dually eligible beneficiaries, full benefit dually eligible beneficiaries and non-dually eligible beneficiaries. The point is to “improve the precision of the payments made to plans, including increases in payments for plans serving full benefit dually eligible beneficiaries,” according to the agency.
More information on the HCC-based risk adjusted payments can be found here.
CPC+ Payer Regions
The 14 regions include:
Kansas and Missouri: Greater Kansas City Region
New Jersey: Statewide
New York: North Hudson-Capital Region
Ohio: Statewide and Northern Kentucky: Ohio and Northern Kentucky Region
Pennsylvania: Greater Philadelphia Region
Rhode Island: Statewide
Along with the announced payer regions, CMS is also adding more informational webinars on various topics within CPC+. Yet more details and fact sheets on CPC+ vendor support, program details and payer requirements can be found here on the CMS CPC+ web page.
Greg Fulton is industry and public policy lead for Wellcentive.