Tuesday May 24, 2016
Why You Should Apply for CPC+ Program
On April 11, CMS announced the establishment of the Comprehensive Primary Care Plus (CPC+) program(www.cms.gov). CPC+ is an advanced primary care medical home delivery and payment model that builds on the Comprehensive Primary Care Initiative (CPCi) program, which was launched in 2012 and concludes at the end of this year.
In its announcement, CMS referred to CPC+ as "largest-ever multi-payer initiative to improve primary care in America." The AAFP welcomed the announcement of the new program. Fundamentally restructuring how we pay for primary care is an important step towards our goal of reforming the health care system to one that is foundational in primary care. The underlying policies of the CPC+ program are consistent with the AAFP policies on primary care delivery system and payment reform.
The program, which is a regionally-based and multi-payer, will launch formally in January 2017 and run for five years. CMS plans to identify and enroll 5,000 practices -- up to 20,000 total participants -- practicing in 20 yet-to-be-identified regions to participate in the program. Up to 2,500 practices will be selected to participate in one of two tracks (5,000 total participants).
Additionally, and probably most importantly, the CPC+ has been identified as an advanced alternative payment model (Advanced APM) under the Medicare Access and CHIP Reauthorization Act, meaning that practices participating in the CPC+ program will be eligible to receive a 5 percent bonus payment on their Medicare allowable charges starting in 2019.
CPC+ is designed to reward primary care physicians for the comprehensive, coordinated, and continuous care they provide their patients. By incorporating a multi-payer approach, the CPC+ program promotes alignment in delivery and payment policies across all payers in a physician’s practice. This means that all patients cared for by that primary care physician practice will be participating in the program versus just a physician's Medicare patients.
Participating practices will be asked to transform their practices to focus on the five core principles of advanced primary care, also known as the Comprehensive Primary Care Functions, which were established as part of the original CPCi program. These five functions, when accompanied by the Joint Principles of the Patient-Centered Medical Home, are consistent with the AAFP’s definition of an advanced primary care practice. The five functions are:
- access and continuity;
- care management;
- comprehensiveness and coordination;
- patient and caregiver engagement; and
- planned care and population health
Clearly, practice transformation consistent with these five functions necessitates payment policies that support such activities. The CPC+ program adheres to the AAFP's long-standing policy that advanced primary care practices should receive advanced payments on a per capita basis for both care delivery and care management. In an April 11 JAMA article(jama.jamanetwork.com), Laura Sessums, J.D., M.D., director of the Division of Advanced Primary Care at the Center for Medicare and Medicaid Innovation, expressed similar sentiments.
"To support fundamental change in care delivery, practices require a fundamental change in payment structure," she wrote.
The CPC+ program is designed to accomplish this goal in three ways.
- Care management -- All practices participating in the program will receive, from Medicare, an advanced care management fee for each attributed beneficiary. They also will receive an advanced care management fee from participating private insurers. The care management fee for CPC+ Track 1 will be determined in four risk tiers, but it is expected to average $15 per beneficiary per month or $180 per year. Track 2 payments will be determined in five risk tiers, but are expected to average $27 per beneficiary per month or $324 per year.
- Performance-based incentive payments -- All practices participating in the program will receive an advanced, performance-based incentive payment for each attributed beneficiary. The per beneficiary incentive payment for practices participating in Track 1 will be $2.50 and $4 for those in Track 2. These payments are designed to both facilitate and reward performance on patient experience, clinical quality, and utilization measures. The payments will be made at the beginning of each year, but will be subject to recoupment if the practice fails to meet its thresholds for the quality and utilization performance.
- Payment reform -- Practices participating in Track 1 will continue to receive fee-for-service payments for services provided to Medicare beneficiaries. However, practices participating in Track 2 will receive a blended payment of a global payment for evaluation and management services and fee-for-service. The advanced E&M payment, referred to as the "comprehensive primary care payment," is designed to pay the practice for the costs of a typical office visit, thus creating flexibility in how the physician delivers care to their patients. More explicitly, the comprehensive primary care payment is designed to create parity in delivery modalities -- face-to-face, telemedicine, phone, etc.
The AAFP sees the CPC+ program as a positive step towards creating and implementing a payment model that aligns with the core functions of an advanced primary care practice. Yes, there are likely things that will need to be tweaked or improved, but we should not allow the perfect to become the enemy of the good. It is important that we have robust participation among family physicians in the CPC+ program -- especially those in solo and small practices. To this end, we are urging family physicians to pursue this opportunity. Enrollment for physicians opens July 15 and concludes Sept. 1.
Additional information and a complete timeline are available on our CPC+ resource page.
If you are interested in learning more about how you can participate in this program please send an email to CPCPLUS@aafp.org. We will follow up regarding how the AAFP can help prepare for your practice for the open enrollment period.
Posted at 07:00AM May 24, 2016