08 Jun CMS Plans to Accept 1,000 Primary Care Practices During CPC+ Round 2
CMS recently announced Round 2 of the Comprehensive Primary Care Plus (CPC+) program, and plans to accept 1,000 primary care practices in Lousiana, Nebraska, North Dakota, New York (Erie County and Niagara County.)
Currently, there are 2,891 Primary Care practices, including 13,090 clinicians, in 15 states participating in CPC+ Round 1. CPC+ allows primary care practices of all sizes and structures to qualify for Advanced Alternative Payment Models incentive payment under the Quality Payment Program.
Applications for CPC+ Round 2 are due July 13, 2017, and the program will begin January 1, 2018.
What Is the Comprehensive Primary Care Plus (CPC+) Program?
CPC+ is a multi-payer initiative to improve primary care in the U.S. The CMS created the CPC+ program under the Innovations Center with the goal of building “capabilities and care processes to deliver patient-centered, high quality care, and lower the use of unnecessary services that drive total costs of care.”
Round 2 will last for five years (2018-2022) and participating practices are expected to stay in the program for its full duration. However, the program is voluntary and participants will be able to withdraw from the model without penalty.
Practices will fall into one of two program tracks. Each tracks dictates which capabilities practices will develop and the payment structure they’ll receive:
- Track 1 will focus on patient access, care management and coordination, patient engagement and population health.
- Track 2 will focus on care management payment, incentive payments for quality and utilization, and offering an alternative to the fee-for-service payment structure.
In order to apply, practices must meet the following requirements:
Tracks 1 and 2:
- Practice must be primary care (family medicine,) internal medicine and geriatrics
- Must be located in CPC+ Round 2 region
- Must have existing care delivery activities such as 24-hour access
- Must have, at least, 125 Medicare Part B fee-for-service beneficiaries
- 45% or more of current revenue is generated from CPC+ payer partners. Although, CMS recommends having 50% or more to be in a better position to meet the CPC+ practice requirements and service delivery model
- Must use CEHRT
- Does not charge a membership or retainer fee to its patients
Track 2 only:
- Developing and recording care plans
- Following up with patients after emergency department or hospital discharge
- Implementing a care coordination system linking patients to community programs and resources
- Letter of support from health IT vendor that outlines the vendor’s commitment to support the practice in optimizing health IT
CPC+ Round 2 Payer Partners
The following payers have been selected for Round 2:
- Louisiana: Amerigroup Louisiana, Inc., AmeriHealth Caritas Louisiana, Inc., Blue Cross Blue Shield of Louisiana
- Nebraska: Blue Cross Blue Shield of Nebraska
- New York: Greater Buffalo Region: HealthNow New York Inc., Independent Health Association, Inc.
- North Dakota: Blue Cross Blue Shield of North Dakota
How Will Practices Be Paid Under CPC+?
- Track 1 practices will receive an average of $15 per beneficiary per month, as a care management fee to support their efforts. Practices in Track 1 will also continue to receive regular fee-for-service payments for evaluation and management (E&M) services.
- Track 2 is a hybrid of fee-for-service and Comprehensive Primary Care payment, and will give practices flexibility for care to be delivered in or out of an office visits. Track 2 practices will receive a percentage of their expected Medicare E&M payment upfront in the form of a Comprehensive Primary Care Payments (CPCP) and a reduced fee-for service payment for face-to-face E&M claims. Under Track 2, practices will receive an average of approximately $28 per beneficiary per month, including a $100 per beneficiary per month for a highest risk tier to support the services needed by beneficiaries with complex needs.
- Tracks 1 and 2 will receive a performance-based incentive payment, which practices may keep if they meet annual performance thresholds. Practices that do not meet the annual thresholds would be required to repay all or a portion of the prepaid amount. CMS will provide larger performance-based incentive payments in Track 2 than in Track 1. For details on the CPC+ payment methodology, click here.
It is important to note that CPC+ practices, cannot bill CMS for Chronic Care Management (CCM) services provided to a CPC+ beneficiary.
Can CPC+ Practice Participate in Other CMS Payment Models?
According to the CMS website, CPC+ practices are able to participate in the following models:
• CPC+ practices may participate in Model 2 and Model 3 of the Bundled Payments for Care Improvement Initiative and the Oncology Care Model. While they would not be participants themselves, CPC+ practices may also engage in sharing arrangements with participant hospitals in the Comprehensive Care for Joint Replacement Model.
• Medicare beneficiaries may be attributed to both CPC+ and Million Hearts® Cardiovascular Disease Risk Reduction model practices, as cardiovascular interventions can be part of, and complementary to, practice transformation.
• CPC+ practices may participate in the Accountable Health Communities (AHC) Model as a bridge organization or be paid through the AHC model by a bridge organization.
• Clinical Practices enrolled in and receiving technical assistance through Transforming Clinical Practice Initiative (TCPI) can apply for CPC+, but, if selected into the CPC+ model, the practice and clinicians must have exited or “graduated” from TCPI effective December 31, 2017. A clinician or practice cannot participate in CPC+ and receive technical assistance from TCPI at the same time. Practitioners providing the technical assistance or serving as faculty resources as part of a TCPI Practice Transformation Network or Support and Alignment Network may participate in CPC+.
CPC+, ACOs, Advanced APMs and the Quality Payment Program
Primary care practices participating in both a Shared Savings Program ACO and CPC+ must adhere to the ACO’s required care processes and implement the CPC+ care delivery requirements.
As mentioned before, CPC+ practices will be evaluated as an Advanced APM under the Quality Payment Program (QPP.) Practices within an ACO will have to forego the CPC+ performance-based payment, and instead will participate in the ACO’s shared savings/shared losses model. For practices participating in an ACO, determination about the Advanced APM incentive will be based upon the Medicare Shared Savings Plan track in which the practice participates.
- MSSP ACO Track 1 is not considered an Advance APM, practices participating in this model will not be considered for the APM incentive payment. Clinicians that don’t participate in an Advanced APM, or don’t meet the Advanced APM requirements for a year, will be subject to MIPS.
- MSSP ACO Tracks 1+, 2 and 3 are considered Advanced APMs. Therefore, clinicians in CPC+ practices who are part of one of these ACO models will be evaluated at the ACO level to determine if they are eligible for the Advanced APM incentive payment.
Is your practice considering applying for the CPC+ Round 2 model? Let us help! We have experts in care coordination, IT, and payment models that can help implement changes necessary to succeed in the Comprehensive Primary Care Plus model. Contact Vicki Perry at Vicki.Perry@shcare.net or fill out the form below.