Late last week, the FAH submitted comments to the Center for Medicare and Medicaid Innovation (CMMI) on a Request for Information (RFI) it issued on a Direct Provider Contracting (DPC) model it is considering. The DPC RFI outlines a new type of model where CMS suggests it could contract directly with participating physician practices to establish those practices as the main source of care for primary care or other services for beneficiaries that voluntarily enroll. CMS considers the use of a fixed per beneficiary per month payment to cover the cost of these services with the expectation that the contracted physician practice would provide those services in a manner agreeable to both CMS and the physician practice.
The FAH urged caution with regard to implementing these types of arrangements, especially due to the potential for significant adverse impact on existing accountable care organizations (ACO) and other CMMI models. The FAH noted that given the time and resources that CMS, providers, and patients have devoted to improving and implementing CMS's existing models, it is imperative that CMS not only continue to devote energy and resources to these models but to also examine how they would be affected by the launch of a new model, in particular whether this new model would disrupt their operations and diminish their performance and potential. As such, prior to implementation of a new model, CMS should consider:
- How would model overlap, hierarchy, and attribution issues be managed? These are areas that have required considerable collaboration between CMS and providers, and the introduction of a new model such as the DPC model could compound them significantly.
- How would the DPC model and similar type models impact participation in existing models? How could patient attribution to new models undermine the success of existing models? For example, it is clear from recent public statements that CMS is interested in pushing the pace of ACOs taking greater levels of financial risk. How will CMS assure providers interested in greater risk that new models will not undermine their investment, by for example, cherry-picking patients?
- How does CMS plan to allocate finite resources to manage existing and new models? CMS's administrative resources are not limitless, and the obligations associated with deploying a new model could result in additional issues with data timeliness, responsiveness, and priority updates for current models.
Given these considerations, the FAH believes CMS is better served in the short-term by devoting its energy and resources to existing models, incorporating a number of the proposals in the DPC RFI into its existing models, and determining how it can build off of the existing models to further reform care delivery.
The FAH's comment letter can be viewed here.