On June 8, 2023, CMS announced a new CMMI primary care model, Making Care Primary (MCP), covering
traditional Medicare beneficiaries, that aims to strengthen primary care infrastructure through service
delivery and care integration enhancements designed to improve an MCP entity’s care management
programming, specialty care integration and community supports connections closing social determinant
of health gaps. The program is meant to provide a progressive roadmap into value-based payment (VBP)
arrangements for primary care clinics with limited VBP experience.
CMS published a MCP Request for Application (RFA) in August with a November 30th, 2023 application
submission deadline.
5 key considerations for health care stakeholders interested in MCP:
- VBP Experience Flexibility & Growth Path
a. CMS encourages and supports model participation for primary care clinics with limited value-based
payment experience, including FQHCs and safety-net providers, through three progressive tracks
(see MCP Participation Track Overview Table below).
i. CMS has frequently cited FQHCs, safety-net providers and independent primary care clinics as
primary examples of provider types for whom the MCP was designed.
- MCP provides novel opportunities for entities beyond its three progressive tracks: this is the
first opportunity provided to FQHCs to participate in a multi-state advanced primary care
model.
ii. All MCP participants must meet CMS eligibility criteria to participate in the model. - Entities eligible to participate in MCP are legally formed, Medicare-enrolled entities billing
health services to a minimum of 125 Medicare beneficiaries with a majority of its physical
office settings in an MCP test state (CO, MA, MN, NC, NJ, NM, NY, WA). - Entities not eligible to participate in MCP are rural health clinics, concierge practices,
current Primary Care First (PCF) practices and current ACO REACH participant providers
that did not terminate by May 31, 2023, grandfathered tribal FQHCs. Entities also may
not concurrently participate in MSSP after the first six months of MCP Primary Care
advancement.
b. CMS will require MCP participants to progress through the three tracks of the program until they
reach Track 3.
i. MCP Participants in Tracks 1 and 2 must progress to the subsequent track in a timeframe yet to
be determined
ii. There are presently no time limits for MCP Participants in Track 3
- Primary Care Advancement
a. CMS will provide MCP participants in all three tracks with prospective, risk-adjusted enhanced
services payments to support primary care advancement.
i. The MCP Participation Track Overview Table (shown in Figure 1) provides an overview of the
parameters governing the three progressive tracks in which MCP entities may participate in the
model:
- Previous level of VBP experience
- MCP participant development expectations
- Payment arrangement
ii. Enhanced services payments will support the development of three core primary care service
delivery capabilities: - Care management development with a focus on chronic condition self-management
- Specialty care integration while leveraging behavioral health screenings
- Community supports and services partnerships to address a patient’s health-related social
needs (HRSNs)
- Health Equity
a. CMS will continue their efforts to achieve health equity through requirements and provisions throughout the model.
i. MCP participants will be required to do the following:
- Develop a “Health Equity Plan”, akin to those required in ACO REACH
- Implement HRSN screening and referrals
ii. CMS will do the following: - Permit MCPs to reduce cost-sharing for patients in need
- Adjust payments by clinical indicators and social risk
- Measure the percentage of patients screened for HRSNs
- Collect data on certain demographic information and HRSNs to evaluate health disparities in MCP communities
- Payer Program Alignment
a. CMS has committed to working with State Medicaid agencies to align MCP with state programs and engaging with private
payers to extend MCP alignment across lines of business (LOBs). This makes MCP a unique opportunity to build valuebased payment and population health management infrastructure and capabilities that will enable success in other value
based payment arrangements with health plans for Medicaid managed care, Medicare Advantage, special needs plans
(D-SNP, C-SNP for instance), ACA exchange and even commercial in some markets.
i. MCP alignment efforts will extend to the following:
- Streamlining core quality measure across payers and CMMI programs and the testing of new and innovative
measures. - Sharing state and national level resources with MCP participants, including practice and patient-level data
- Providing support for success across MCP activities, including, but not limited to, state-level data aggregation and
reporting, specialty care data, practice coaching and peer-to-peer learning
- Decade-Long Term
a. CMS announced a 10.5 year-long term for the program, from July 1, 2024, through December 31, 2034, amongst the longest
initial proposed term in a CMMI model in recent years.
b. CMS will begin accepting applications for MCP later this summer.
Your Trusted Partner for VBP Success
COPE Health Solutions (CHS) is a national tech enabled services firm with unparalleled CMS, CMMI and State Medicaid Waiver
model experience that leverages deep expertise, proven tools, and processes across key VBP functions to drive success for all
delivery system stakeholders.
CHS is prepared to support the development of your organization’s key VBP domains listed below for success in the MCP and its
alignment with its programs across all LOBs, including Medicare FFS, MA, Medicaid, Employer-Sponsored Plans and Commercial
insurance.
Turn-Key VBP and PHM Data Warehouse, Management Reporting, Analytics and Workflow Integration with comprehensive wraparound expertise and support functions
- EMR integration capabilities and easy to use benchmarking and PCP dashboarding tools with provider and member specific
chase lists for CDQI (risk adjustment), quality, total cost of care and clinical continuity - SDoH integrated risk stratification and performance measure reporting critical to delivering actionable data for both medical
and social care needs - Role based analytics output integration of actionable data and reports into workflows
- Integrated evidence based practice transformation tool
- Wrap-around industry expert advisory, implementation, interim management/staffing and “co-management” support in the
areas of strategy/value based payment roadmap; care management and medical management; health plan and provider
contracting; IPA/CIN development and optimization; practice transformation; clinical workflow redesign and specialty
alignment including referral and e-consult; physician and member portal implementation and optimization; and comprehensive
management services organization (MSO build, implementation and operations; and rapid, scalable recruitment, training and
education and retention programs for medical assistants, care coordinators, nurse practitioners, physician assistants and other
essential roles
Contact us at info@copehealthsolutions.com to learn how we can help your organization achieve success in value-based payments.