Making Care Primary (MCP) model

Executive summary

This article describes:

• Key features of the new Making Care Primary (MCP) model
• Eligibility criteria and timelines to apply for and participate in the new model
• Key considerations for interested applicants

Highlights

• Providers:  Financial incentives for providers new to value-based care (VBC) will enable additional infrastructure funding and value-based payment (VBP) bonus payments with zero or minimum risk exposure (varying based on track selected)
• Payers:  Partnership with CMS will foster alignment to reduce clinician burden and payer fragmentation, allowing providers to focus on practice transformation that will further result in cost savings and improved quality of care as providers move from fee-for-service (FFS) to VBC

Introduction

On Sept. 4, 2023, the Center for Medicare and Medicaid Innovation (CMMI) began accepting applications for the recently announced Making Care Primary (MCP) model. The MCP is a multi-payer model that will run for 10 years, beginning July 2024 and ending December 2034. Providers interested in participating in the new model can submit applications via the CMS web portal until Nov. 30, 2023.

The MCP mirrors previous CMMI Alternative Payment Model (APM) goals of incentivizing providers to improve quality outcomes and reduce unnecessary healthcare costs for “traditional” Medicare Fee-for-Service (FFS) beneficiaries.

Similar to the Medicare Shared Savings Program (MSSP), the MCP model offers progressive "tracks” to help encourage participation from a broad range of providers to advance CMMI’s goal of transitioning the current FFS healthcare system to one that pays for value rather than volume.

CMMI & model goals

CMMI is dedicated to developing new healthcare payment and service delivery models to reduce Medicare program expenditures, while simultaneously enhancing quality of care furnished to Medicare FFS beneficiaries.

Under the Biden Administration, CMMI has been launching new models to advance additional goals of achieving equitable outcomes through high-quality, affordable, person-centered care. To achieve these goals, CMMI is implementing a strategic refresh organized around five key objectives to be incorporated into all new APMs.

The new MCP model is no exception and promotes the following goals in alignment with CMMI’s objectives:

• Ensure beneficiaries receive primary care that’s integrated, coordinated, person-centered and accountable
• Create a pathway for primary care clinicians to adopt prospective population-based payments and become more accountable for cost and quality of care
• Advance health equity by focusing on reducing disparities and addressing health-related social needs
• Focus on partnerships between the state, payers and stakeholder/beneficiary engagement

Eligibility criteria

The MCP model was designed to incentivize broader participation of primary care clinicians, especially small and independent providers and rural organizations supporting underserved communities. Applicants interested in participating in the MCP model must meet the following eligibility criteria:

• Be a legal entity formed under applicable state, federal or tribal law authorized to conduct business in each state in which it operates
• Be enrolled in Medicare
• Bill for health services furnished to a minimum of 125 attributed Medicare beneficiaries
• Have a majority (51%) of their physical primary care locations located in one or more of the following MCP eligible states/regions: Colorado, North Carolina, New Jersey, New Mexico, Minnesota, Massachusetts, Washington and upstate New York¹

Entities not eligible for MCP:

• Rural health clinics
• Concierge practices, which collect a fee from patients for access to their services
• Participating providers in the ACO REACH and Primary Care First (PCF) models
• Grandfathered tribal FQHCs

Organizations cannot concurrently participate in MSSP and MCP after the first six months of the model.

Provider participant opportunities

Key features and benefits

• Organizations that do not have prior VBC experience have the opportunity to gain up-front infrastructure payments and, over phases, shift from FFS to population-based payment. In addition, there is no downside adjustment based on performance; rewards focus on key clinical outcomes first
• Participants will receive specialty integration payments and specialty care performance data to improve collaboration and drive transformation
• Increased payments will be provided to participants for patients with more intensive needs in order to advance health equity
• Support will be provided to participants to achieve model goals, including coaching for small organizations and partnerships with payers

Payer opportunities

Key features and benefits

• Ongoing partnership and collaboration with CMS
• CMS will work with payers to share data with program participants. This will be built into existing state infrastructure to increase efficiency
• Reduced reporting burden for quality measures, data exchange, etc.
• Cost savings and improved quality of care as participants move from FFS to VBC

Payment options

To incentivize and encourage broader provider participation, the MCP model offers flexibility for participants to select from three progressive “tracks.” The tracks are designed to accommodate providers with a varying value-based payment experience and offer various levels of financial support payments to help providers build infrastructure and advanced care delivery capabilities.

Tracks will have specified time limits to progressively shift providers to increased levels of accountability for cost and quality outcomes. Participants that begin their model participation in tracks 1 and 2 must move to the next track level after specified time periods, while participants that start in track 3 will remain in track 3 for the full duration of the model. Note that organizations that start in track 2 or 3 may not “move down” to track 1 or 2, respectively.

CMS will provide the most financial support to assist participants with no prior value-based experience in track 1; financial support will be progressively reduced as participants move to tracks 2 and 3. Participants will use these financial payments to build up their infrastructures and workflows to advance their value-based care delivery capabilities and performance.

Payment types

• Prospective primary care payment (PPCP): Replace fee-for-service revenue for primary care services for beneficiaries attributed to MCP. Will reflect participant’s historical primary care billing for the first three model years; CMS will introduce a methodology that bases a portion of the PPCP on regional spend trends for track 3 participants.
• Enhanced services payment (ESP): Risk-adjusted per beneficiary per month (PBPM) payment to participants in tracks 1, 2 and 3 in addition to payment for typical primary care services; decreases by track as participants build capacity. Support ongoing care management activities, such as chronic disease management and health-related social needs (HRSN) screenings.
• Performance incentive payment (PIP): Upside risk only bonus payment based on quality utilization and cost; bonus potential increases by track. Assessed annually.
• Upfront infrastructure payment (UIP): Infrastructure payment that’s only available to track 1 participants new to VBC arrangements and who meet a low revenue threshold or don’t have an e-consult platform. Eligible participants may receive $72,500 in a lump-sum payment at the start of year 1 and an additional $72,500 at the start of year 2.

Model timelines

CMMI officially released RFAs to apply for the MCP on Sept. 4, 2023, with closing on Nov. 30, 2023. CMMI will announce the selected MCP participants in 2024 and begin onboarding participants from April to July 2024.

The MCP model’s first performance year (PY) is scheduled to launch on July 1, 2024, and will continue through December 2034.

This innovative model offers a unique opportunity for providers to participate in a 10-year program designed to reward providers who can demonstrate their ability to improve healthcare delivery and quality of care. Many provider groups and IPAs are already familiar with value-based care delivery and could create a new revenue stream by participating in this unique program.

Get in touch with us to learn more about the Making Care Primary model and discuss important considerations for your organization.

Authors

Devon Judge, Director, Healthcare Consulting

Maheen Noon, Manager, Healthcare Consulting

Elizabeth Hutman, Senior Consultant, Healthcare Consulting

Footnote 

[1] Only specific counties in New York State are eligible to apply; for the other States, all counties may apply

References

1. Image 1: https://www.cms.gov/es/node/2078396
2. Text sources:
   1. https://www.cms.gov/files/document/mcp-rfa.pdf
   2. https://www.cms.gov/priorities/innovation/media/document/mcp-ovw-fact-sheet
   3. https://www.cms.gov/priorities/innovation/innovation-models/making-care-primary
   4. Making Care Primary (MCP) Model Frequently Asked Questions | CMS
   5. https://www.cms.gov/priorities/innovation/media/document/mcp-payer-partner-fact-sheet
   6. https://www.cms.gov/priorities/innovation/media/document/mcp-fqhc-webinar-slides
   7. https://www.cms.gov/files/document/mcp-payer-oh-slides.pdf

The information provided here is for general guidance only, and does not constitute the provision of tax advice, accounting services, investment advice, legal advice, or professional consulting of any kind. The information provided herein should not be used as a substitute for consultation with professional tax, accounting, legal or other competent advisers.