May 17, 2019
On April 22, 2019, CMS announced the CMS Primary Cares Initiative, a set of five new payment models available to primary care practices and other providers under two new paths: Direct Contracting and Primary Care First. Both paths are focused on transforming the delivery of primary care. The three Direct Contracting models aim to engage organizations that serve large patient populations and have experience with financial risk tied to patient care outcomes. These models provide risk-adjusted, capitated monthly payments based on patient populations and give providers the option to take on half or full-risk for shared savings and losses. Two of these models, the Professional and Global Population Based Payment models, are open for application and will begin in January 2020. To be considered for these programs during the initial application period, providers need to submit a Letter of Intent to CMS by August 2, 2019 at 11:59 pm EDT.
CMS is seeking public comment on the remaining Direct Contracting model, the Geographic Population Based Payment Plan. The request for information related to this model is open until May 23, 2019 at 11:59 pm EST. Subject to responses received in the request for information, CMS expects to initiate the application process for the Geographic Population Based Payment model in the fall of 2019.
The two Primary Care First payment models are targeted to small primary care practices and aim to relieve revenue cycle burdens by providing payments through a simple monthly payment structure with value-based incentives. The model will begin in January 2020 for the first cohort of payers and practices. These practices and payers must be located within specified regions, must have signed the Primary Care First Participation Agreement with CMS, and cannot be currently participating in the Comprehensive Primary Care Plus program. CMS anticipates releasing a Request for Application soon for this cohort of payers and practices. If you have any questions about the Primary Cares Initiative, or would like guidance while navigating the application process, please contact Jim Daniel or Mark Watson.
The information contained in this advisory is for general educational purposes only. It is presented with the understanding that neither the author nor Hancock, Daniel & Johnson PC, is offering any legal or other professional services. Since the law in many areas is complex and can change rapidly, this information may not apply to a given factual situation and can become outdated. Individuals desiring legal advice should consult legal counsel for up-to-date and fact-specific advice. Under no circumstances will the author or Hancock, Daniel & Johnson PC be liable for any direct, indirect, or consequential damages resulting from the use of this material.
