Making Care Primary Model: 5 crucial things to know

On June 8, CMS announced the new Making Care Primary Model that will run for 10.5 years, from July 1, 2024, to Dec. 31, 2034. To ensure you’re ready for the application process, this blog will explain what you need to know about MCP.

What is Making Care Primary?

The MCP model aims to make advanced primary care more available and sustainable. This model builds upon previous innovative primary care models over the past 10 years, including the Comprehensive Primary Care Initiative, Comprehensive Primary Care Initiative Plus and Primary Care First.

State participation in MCP

CMS announced that the MCP multi-state initiative will be tested under the Center for Medicare and Medicaid Innovation in eight states: New York, Massachusetts, New Jersey, North Carolina, Minnesota, Colorado, New Mexico and Washington.

Based on what we know so far, let’s dive into the top five things you’ll need to know about this program.

1. MCP lasts 10.5 years

The model duration (10.5 years) for the CMS MCP model is significantly longer than most other CMMI models, which have spanned around five years.

Shorter-span models can be difficult to evaluate, especially if issues related to policy changes and participant selection bias arise partway through. Thus, expanding the model to 10.5 years offers a strong opportunity for CMMI to test the effectiveness of the model and observe positive primary care outcomes.

2. Attractive for primary care practices with little to no value-based care experience

MCP will be highly attractive to primary care practices with little to no VBC experience. CMMI appears to be making a substantial effort to ease some of the upfront barriers to participation that have historically impeded many small, rural and safety net organizations from entering VBC arrangements.

There is an option to receive an upfront infrastructure payment for low-revenue, inexperienced organizations entering Track 1 (see more on this later). This would provide those organizations the funds to build their capacity to offer advanced primary care services. This effort by CMMI has some similarities with a new advance incentive payment option offered for new low-revenue, inexperienced entrants into the Medicare Shared Savings Program Accountable Care Organization program beginning in January 2024.

3. Organizations participating in PCF and ACO Reach as of May 2023 can’t enter MCP

Organizations that are already participating in Primary Care First and ACO Reach as of May 2023 cannot enter MCP. Organizations in the MSSP can enter MCP if they withdraw from MSSP prior to January 2025. CMMI does not want outmigration from PCF and ACO Reach to affect MCP. This would create a selection bias and impact the evaluation of those ongoing models.

4. MCP offers a three-track design

The design is meant to engage healthcare organizations with varying levels of experience. The tracks gradually transition participants from the traditional fee-for-service payment system to a model with full capitation. The level of VBC experience will inform at which track organizations can enter MCP — this is yet to be explicitly defined. The expectation is organizations will aim to enter MCP at the lowest tier possible.

5. There are six payment elements in MCP

Some of the six payment elements apply across all tracks, whereas others are only applicable for certain tracks. These payments include:

• Upfront infrastructure payment: Optional startup funding for low-revenue organizations inexperienced with VBC that enter MCP at Track 1. CMS will recoup funds from organizations that terminate participation prior to entering Track 3.
• Enhanced services payment: A per beneficiary per month payment that is made prospectively on a quarterly basis to develop capabilities and provide enhanced primary care services. The PBPM payment amount will be determined at a beneficiary level based on low-income subsidy enrollment, CMS Hierarchical Condition Categories clinical risk and Area Deprivation Index social risk.
• Prospective primary care payment: This PBPM payment is to transition organizations from traditional fee-for-service to and population-based payment structure. This will replace 50% of FFS revenue for Track 2 participants and 100% of FFS revenue for Track 3 participants.
• Performance incentive payment: An upside-only performance incentive payment based on improvement in patient outcomes and quality measures. The range of upside adjustment is substantially larger at higher tracks:
  • Track 1: Up to 3% of FFS;
  • Track 2: Up to 45% of FFS + PPCP; and
  • Track 3: Up to 60% of PPCP.
• MCP e-consult: Enables primary care clinicians to bill for post-service time spent implementing specialist recommendations, allowing for better care delivery coordination. Note: this only applies in Tracks 2 and 3.
• Ambulatory co-management: Additional monthly payment billable by specialty care partners for short-term specialized care to support collaboration when stabilizing patients with an exacerbated chronic condition in cardiology, pulmonology and orthopedics. This is for Track 3 only.

Making Care Primary application deadline and timeline

Organizations interested in participating can submit a voluntary, non-binding letter of intent to CMS. In mid-August, CMS will release the request for applications and open the application portal. CMS will accept applications through November 2023. The MCP model is expected to go live July 1, 2024.

Considerations for participation

In the meantime, primary care organizations considering applying to MCP should appraise their readiness to participate. Practices that have adopted patient-centered strategies into their daily care delivery are ideal candidates for this model. You’ll need to consider the following eight items to properly prepare:

1. Patient-centered medical home recognition, or desire to achieve PCMH;
2. policies that have been implemented to structure workflow and promote consistency;
3. care coordination efforts across the medical neighborhood;  
4. pathways of access available to patients;
5. clinical outcome and patient experience analysis and how/if it is being applied to define overall care;
6. relationships with partners in the care continuum;
7. technologies to assist with maximizing results and using the functionality offered; and
8. the culture within your organization to tackle this shift in how care is delivered.

Need assistance preparing your application? DataGen can help.

This new model comes with exciting opportunities for primary care practices. If you’re interested in putting together a successful application, lean on DataGen’s experts to give you the robust data and guidance you need. Contact us today to discuss applying for MCP or request more information about our services.