Healthcare officials and groups offered the Center for Medicare and Medicaid Innovation (CMMI) feedback on its Direct Provider Contracting model, which would involve agreements be between payers and primary care or multi-specialty groups in Medicare fee-for-service, Medicare Advantage and Medicaid.
Healthcare organizations that support DPC said it could increase chances for physician groups to participate in alternative payment models (APMs).
Groups that opposed the measure said there are still too many questions about DPC and CMS should fix the Medicare Shared Savings Program (MSSP) rather than introduce another, potentially redundant model.
The DPC model gives physicians two-sided risk through direct contracting with Medicare plan payers. Providers would be accountable for the care of a specific beneficiary population, likely through per member per month payments, and could receive performance-based rewards. CMS said the proposal furthers its goals of pursuing value-based care models while also reducing red tape and reporting burdens for providers.
The request for information last month on DPC was part of a larger plan to rework the innovation center. The current administration at CMS has moved away from some CMMI models, like mandatory bundled payment programs, but says paying for value is still a core concept moving forward.
In its letter about the DPC proposal, the Medical Group Management Association said CMMI must make reducing those burdens a priority in the DPC model. MGMA said it backs the idea and added it could increase opportunities for physician practices to participate in advanced APMs, one track under MACRA that has been criticized for not having enough eligible models.
However, MGMA requested CMMI commit to “to involving physician group practices of all sizes and specialties through attainable benchmarks, robust incentives, upfront investment support, data sharing and tools for patient engagement. Without this commitment, the DPC model could drive further consolidation among healthcare providers while forcing independent practices out of business — actions which restrict patients’ access to care,” the group wrote.
The National Association of ACOs also backs the DPC concept, but suggested CMMI only roll it out to primary care initially. The group said DPC should be a voluntary program and kept to primary care because specialty DPC models would be too similar to bundled payment programs. Also, structuring per beneficiary per month payments for specialty care would be too complicated, it said. The association added that DPC should include ACOs, and many are interested in testing the concept.
America’s Physician Groups (APG) also liked the idea and proposed its own plan, which is called the third option. APG said its plan “mimics the integrated, capitated payment and delivery model used by APG members across the country in virtually all other programs and products.” The plan would use clinically integrated organizations that are physician-centric, but providers could have different levels of risk and accountability.
However, not everyone is supportive of the DPC. In the American Hospital Association (AHA) response, Thomas Nickels, executive vice president of government relations and public policy, said there are too many unanswered questions about the program, and hospitals won’t know whether to participate unless these issues are addressed. “We urge CMS to develop the model as transparently as possible so that potential participants can make fully informed decisions about participation,” AHA said.
The American Medical Group Association (AMGA) also spoke out about the DPC proposal. Rather than creating an additional payment model, AMGA said that CMS should improve the MSSP ACO. Jerry Penso, CEO of AMGA, wrote that providers in the MSSP “are invested in the ACO model and recognize there are flaws in the program that need to be addressed,” such as financial benchmarking, risk adjustment and quality measurement.
Pursuing DPC would be redundant and only compromise MSSP, as providers split between models with the same goals, Penso said.