Noting that physicians practicing within APMs have made significant investments, the Feb. 15 letter said HHS must make “a commitment to transparency and stability in existing models” while working with the physician community when improvements are needed. “Participating practices need assurance that models will not be abruptly ended or changed without their input.”
The letter was sent to HHS Secretary Xavier Becerra, CMS Administrator Chiquita Brooks-LaSure, and Center for Medicare and Medicaid Innovation Deputy Administrator and Director Elizabeth Fowler. It was signed by the Academy, the AMA and the American College of Physicians.
The AAFP's latest expression of support for APMs followed February criticism of the direct contracting model by some in Congress.
Responding to this criticism — and delivering a win for the Academy’s advocacy — CMS on Feb. 24 announced a revision of the combined global and professional tracks of the Direct Contracting Model. Renamed the ACO REACH (Accountable Care Organization Realizing Equity, Access and Community Health) Model, it will include a health equity benchmark to support care services for patients in underserved communities when it begins on Jan. 1, 2023.
“Current GPDC Model participants must maintain a strong compliance record and agree to meet all the ACO REACH Model requirements by Jan. 1, 2023, to continue participating in the ACO REACH Model as ACOs,” the agency said.
Ahead of formally examining this change, the Academy on Twitter praised the focus on equity.
“We share CMMI’s goal of ensuring underserved populations benefit from value-based care,” the tweet said. “The AAFP is reviewing today’s announcement in greater detail. We look forward to partnering with CMMI to improve equitable access to person-centered primary care by advancing physician-led accountable care models.”
The revised plan’s governance requirements promote physician-led accountable care organizations, in line with the Academy’s advocacy because it better reflects the wishes of physicians and patients. REACH’s governing boards will include a beneficiary representative and a consumer advocate with voting rights, a signal of the increased commitment to person-centered care that is called for in CMMI’s 2021 “strategy refresh.”
CMMI’s refresh laid out several goals to accelerate the adoption of value-based care, including 100% enrollment of Medicare beneficiaries in an accountable care relationship by 2030. Calling that goal “essential to the long-term wellbeing of the Medicare program and its ability to meet the needs of a diverse and aging population,” the Academy and its co-signatories reminded regulators in their Feb. 15 letter that advanced primary care and accountable care models “are central to achieving this.”
The letter added that participation in alternative payment models “requires significant upfront and ongoing investment from physician practices” and said such practices, “need a stable suite of multi-payer models that provide predictable, prospective revenue streams adequate to meet patient and practice needs.”
“Improving the transparency and stability of models will foster trust and encourage participation among physicians, and ultimately advance the administration’s goals,” the groups wrote.
The Academy has sounded this warning before. Last year, the AAFP called on CMMI to create a pathway for Comprehensive Primary Care Plus practices stranded by the model’s unexpected termination to transition to a different APM. Such startling changes, that letter cautioned, were likely to send clinicians retreating to fee-for-service practice, undermining the agency’s drive to value-based payment and undervaluing primary care services.