In the immediate aftermath of the Center for Medicare and Medicaid Innovation’s (CMMI) announcement of Comprehensive Primary Care Plus (CPC+), we have fielded numerous questions regarding the interplay of this new program with other Medicare initiatives. Specifically, we have been asked how a provider should decide between participating in CPC+ and joining or continuing to participate in a Medicare Shared Savings Program (MSSP) accountable care organization.
The 2,188 providers in the 445 practices now participating in the predecessor to CPC+, the Comprehensive Primary Care Initiative (CPCI), applied for that program in 2011, prior to the launch of the MSSP. Because CPCI providers are eligible to receive shared savings payments, they have not been eligible to participate in the MSSP.
Unlike CPCI, CPC+ does not have a shared savings component. Instead, CPC+ providers will receive a prepaid incentive payment of $2.50 (Track 1) or $4.00 (Track 2) per beneficiary per month. The provider will be required to repay some, or all, of this amount based on specified quality and efficiency measures scores. Despite the lack of any shared savings payment, CPC+ providers will be prohibited from participating in the MSSP.
CMMI’s decision to prohibit dual participation in CPC+ and MSSP threatens to undo the significant gains many MSSP ACOs have made in care coordination and collaboration among primary care providers, specialist physicians, and other providers. ACOs will now face the difficult challenge of proving to primary care providers – on which ACOs rely for beneficiary attribution – that waiting several months for any payout is a better deal than the immediate payment received under CPC+. If unable to meet this challenge, these ACOs may be forced out of the MSSP, as they lose current primary care participants and are unable to recruit new primary care participants.
As we noted in our prior blog entry, this problem is compounded by the fact primary care providers will not know until late June or early July whether their region has been identified for CPC+ participation. Thus, it is likely these providers will agree to participate (or continue to participate) in an MSSP ACO conditioned upon their selection for CPC+. Such uncertainty makes it difficult for all parties to make the investments necessary for MSSP success. Certainly this is not what CMMI intended with CPC+, but now it needs to deal with this unintended consequence head-on.
