AAFP to CMS: Ease Repayment Pressure on CPC+ Practices

Window Between Reporting and Collection Too Narrow, Academy Says

October 17, 2018 12:01 pm News Staff

The AAFP is calling on CMS to reconfigure a timetable so it doesn't squeeze family physicians taking part in the pioneering Comprehensive Primary Care Plus (CPC+)(innovation.cms.gov) program.

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In early September, CMS notified CPC+ practices that 2017 Performance-based Incentive Payment (PBIP) reports would be available on or around Sept. 26 -- and that the agency would begin charging interest on any required repayment of PBIP funds that were not made by Oct. 18, less than a month later.

"We are concerned that the short timeframe of three weeks after the reports are available is not a reasonable amount of time for a medical practice to respond -- especially given the 19-month minimum gap between performance and payment," the AAFP told CMS Administrator Seema Verma, M.P.H., in an Oct. 12 letter(2 page PDF) signed by Board Chair Michael Munger, M.D., of Overland Park, Kan.

The Academy recommended an adjustment to that repayment timeframe that would bring it into parity with initiatives such as the Medicare Shared Savings Program for accountable care organizations, which gives participants 90 days to repay shared losses.

CPC+, a five-year primary care medical home delivery and payment model, began in 2017. The model remains, the AAFP's letter noted, "beneficial to primary care practices by providing access to increased prospective payments that support comprehensive, longitudinal care."

Every CPC+ practice receives a prospective PBIP at the start of each year. Practices may have to repay all, some or none of the PBIP, depending on quality and utilization performance.

However, the Academy's letter cautioned that the three-week window outlined last month is too abbreviated a period for physicians to both analyze performance data and, if required, send a check to CMS. If the terms remain in place, a program feature designed as an incentive could instead discourage participation in future moves toward value-based medicine.

The letter said that as CMS and the agency's Center for Medicare & Medicaid Innovation "pursue further payment models and work to encourage the successful adoption of more alternative payment models, the AAFP strongly urges CMS to waive interest charges, grant practices more time to understand their payment reports and ultimately respond to CMS requests."

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