In response to CMS' recently issued request for information(innovation.cms.gov) on a proposed direct provider contracting model, the AAFP made some requests of its own: Consider a model in which "DPC" stands for direct primary care, and look for solutions in the Academy's Advanced Primary Care Alternative Payment Model (APC-APM).(38 page PDF)
CMS' proposed new payment model aims to reduce administrative burden and increase flexibility for physicians in exchange for greater accountability for cost and quality.
By any name, primary care practices are undervalued. To correct payment inequities typically felt by family physicians, the AAFP said in a May 25 letter(22 page PDF) to CMS Administrator Seema Verma, M.P.H., that the agency should "consider increasing payments to primary care in any primary care direct provider contracting model."
The letter, signed by Board Chair John Meigs, M.D., of Centreville, Ala., includes a detailed addendum that calls on CMS to make it easy for Medicare beneficiaries to see family physicians in direct primary care practices.
In that addendum, the Academy provided CMS with recent data to support a focus on direct primary care: Results of a March 2018 survey noted that 5 percent to 6 percent of AAFP members practice in, or are working to reconfigure their practices to, this model.
"Highly functioning DPC practices have an opportunity to provide high-quality care at a reduced cost. They also have an opportunity to preserve the independent physician practices that are so critical to our health care system," the addendum noted.
Meanwhile, nearly 70 percent of AAFP members accept new Medicaid patients. This, the letter points out, "demonstrates how family physicians share the direct provider contracting model's goal of ensuring access."
Given these factors, the AAFP urged CMS "to investigate how they can help remove the legal barriers that currently prevent patients from receiving care from family physicians practicing in a DPC practice."
The letter also reminded CMS that the AAFP's design for a new multipayer APC-APM aligns with CMS' goals. In fact, the recommendations in the AAFP's response to the proposal "are based on our extensive work developing the APC-APM model with our members and stakeholders, and the feedback and development that occurred in 2017 with the Physician-Focused Payment Model Technical Advisory Committee." In December 2017, the committee recommended that the APC-APM be rolled out for testing, and it remains under review.
The APC-APM dovetails with CMS' goals for direct provider contracting in several ways. Both models include
- an emphasis on increasing access to high-value, comprehensive primary care;
- a reduction in administrative burden; and
- stable revenue streams and performance-based payments that will allow physicians to invest in their practices.
In addition, both models include per-beneficiary, per-month payments (PBPMs) that would ensure "a consistent and predictable revenue stream that supports the physician-patient relationship and practice transformation." But PBPMs, the letter added, should be risk-adjusted to consider patient demographics, health status and social determinants of health.
The AAFP emphasized that monthly fees should be paid at no risk to the physician and with no cost-sharing requirements from patients. The idea is for such bundled payments to significantly reduce the administrative burdens associated with filing claims.
The letter also urged CMS to reduce physicians' administrative burden by harmonizing quality, patient experience and utilization data practices consistent with the work of the Core Quality Measures Collaborative.
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