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Federal Policy Updates

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PCPCC Submits Detailed Feedback to CMS on Proposed 2017 Medicare Physician Fee Schedule

September 6, 2016

On September 6, 2016, the Patient-Centered Primary Care Collaborative (PCPCC) submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule for the 2017 Medicare Physician Fee Schedule.

In the letter, the PCPCC advocates for the continued transition from volume-driven, fee-for-service payment toward risk-adjusted comprehensive primary care payment. The PCPCC also included specific comments on several issues related to high-performing primary care including:

  • improving payment accuracy for primary care, care management, and patient-centered services;
  • telehealth services;
  • behavioral health;
  • the Comprehensive Primary Care Plus Initiative;
  • the Medicare Shared Savings ACO Program;
  • expansion of the Medicare Diabetes Prevention Program; 
  • and provisions of the Medicare Access and CHIP Reauthorization Act (MACRA).

View the PCPCC's complete response in the PDF attachment below: 

PCPCC Pleased by Federal Announcement of 14 Regions Selected to Participate in Comprehensive Primary Care Plus Initiative

August 1, 2016
FOR IMMEDIATE RELEASE
August 1, 2016
Statement Attributable to:
Marci Nielsen, PhD, MPH
President & CEO
Patient-Centered Primary Care Collaborative

PCPCC Pleased by Federal Announcement of 14 Regions Selected to Participate in Comprehensive Primary Care Plus Initiative

Designed to improve quality and cost, CPC Plus offers an important opportunity for primary care practices to become advanced alternative payment models under MACRA

“Today, the U.S. Centers for Medicare & Medicaid Services (CMS) announced the 14 regions that will participate in the Comprehensive Primary Care Plus (CPC+) Initiative, the largest-ever initiative to transform and improve how primary care is delivered and paid for in America. CMS also opened the application period for practices in the selected regions that wish to participate in CPC+. They can apply from now through Sept. 15.

The Patient-Centered Primary Care Collaborative (PCPCC) is pleased that all seven of the original CPC regions will continue to support multi-payer primary care payment reform by participating in CPC+.  Early evaluations of the original CPC demonstrated measured improvement in total monthly Medicare expenditures ($11 per beneficiary per month), as well as some summary measures of quality of care for patients with diabetes. In addition, the independent evaluators identified important opportunities to further scale and spread high performing primary care. These ‘lessons learned’ are incorporated into CPC+ and represent the next step in advanced primary care for both care delivery and payment design.

The CPC+ initiative represents the future of health care. It encourages the type of comprehensive primary care that not only leads to more effective, efficient, and patient-centered care but also embraces value. It moves us a significant step forward in providing the necessary payment structures to enable primary care providers to operate as high functioning patient-centered medical homes.

Participating CPC+ practices will qualify as Advanced Alternative Payment Models (AAPMs) under the Medicare Access and CHIP Reauthorization Act (MACRA), or new Quality Payment Program (QPP). As an AAPM, CPC+ practices can reap significant financial rewards in 2019 and beyond under the QPP.

As we await the final rule (due in November) outlining specifics of MACRA implementation, we fully support the inclusion of all CPC+ practices as AAPMs. We also strongly advocate for an expansion of pathways, in addition to CPC+, for primary care practices to qualify as AAPMs. Innovative practices should leap at the opportunity for enhanced payment as they shift away from the traditional and inequitable fee-for-service reimbursement model.

We encourage stakeholders to access the CPC+ resources available online:

The PCPCC has long advocated for this type of multi-payer evolution in health delivery and payment reform. Decades of research has shown that health care systems built on a strong foundation of comprehensive primary care lead to better care, smarter spending, and healthier people. CPC+ combines the power of comprehensive primary care with much needed payment reform."

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Editor's Note: To arrange an interview with Marci Nielsen, contact Amanda Holt, 202-640-1212, or amanda@pcpcc.org. We also invite you to access our online Primary Care Innovations and PCMH Map where we track these types of advanced primary care programs nationwide. You can view the CPC+ initiative listed on our map here.

About the PCPCC
Founded in 2006, the PCPCC is a not-for-profit membership organization dedicated to advancing an effective and efficient health care system built on a strong foundation of primary care and the patient-centered medical home (PCMH). The PCPCC achieves its mission through the work of its volunteer members, Stakeholder Centers, experts, and thought leaders focused on key issues of delivery reform, payment reform, patient engagement, and benefit design to drive health system transformation. For more information, or to become an executive member, visit www.pcpcc.org.

PCPCC Responds to Proposed MACRA Regulations

June 27, 2016

On June 27, 2016 the PCPCC responded to the Centers for Medicare & Medicaid Services (CMS) with its official comments on the Medicare Access and CHIP Reauthorization (MACRA) proposed rule.

As a key supporter of payment reform embodied in MACRA, we appreciate CMS’ substantial work in crafting proposed regulations that seek to implement this critically important and complex statute. Leading a careful, clear, and workable implementation of this historic law is an immense challenge, but its importance cannot be overstated. 
 
The PCPCC is particularly supportive of provisions in the MACRA proposed rule that:
  • Acknowledge the key role of Patient-Centered Medical Homes in health system delivery reform. 
  • Improve Quality Measurement and Reporting, to include Patient Reported Outcome Measures. 
  • Advance the Comprehensive Primary Care Plus (CPC+) program as an Advanced Alternative Payment Model.
  • Promote New Categories within the Clinical Practice Improvement Activities (CPIA), including Achieving Health Equity and Integration of Behavioral and Mental Health.
  • Elevate the Physician-Focused Payment Model Technical Advisory Committee (PTAC) 
Despite the complexity of the law itself, the proposed rule in its current form is cumbersome and ill-timed, misses the mark on opportunities to simplify and streamline aspects of performance measurement, and unnecessarily limits the scope and spread of the medical home model of care that could enhance health care delivery to beneficiaries across the US. 
 
The PCPCC offers specific suggestions for improving the implementation of MACRA:
  • Embrace Medical Homes as Advanced Alternative Payment Models
  • Expand Accreditation of Patient-Centered Medical Homes to other recognition programs that have a demonstrated track record
  • Acknowledge the Challenges of Solo and Small Group Practices by promoting virtual groups
  • Change the Implementation Timeline to Give Clinicians More Time to Prepare
  • Streamline Quality Measurement by including the Core Measure Set
  • Strengthen Beneficiary Engagement at All Levels of Care
As a unique coalition representing health care providers, patients, and payers, the Collaborative stands ready to assist CMS in engaging the diversity of organizations keenly interested in supporting payment reform that supports high-performing team-based patient-centered primary care for all. We respectfully request consideration of our recommendations to simplify, spread, and scale high-performing primary care.

PCPCC Applauds Federal Government’s New & Largest-Ever Multipayer Initiative to Improve Primary Care

April 11, 2016
FOR IMMEDIATE RELEASE
April 11, 2016
Statement Attributable to:
Marci Nielsen, PhD, MPH
President & CEO
Patient-Centered Primary Care Collaborative

PCPCC Applauds Federal Government’s New & Largest-Ever Multipayer Initiative to Improve Primary Care

Designed to improve quality and cost, Comprehensive Primary Care Plus expands multi-payer investment in primary care medical homes

“The Patient-Centered Primary Care Collaborative (PCPCC) commends the Centers for Medicare & Medicaid Services (CMS) for creating the Comprehensive Primary Care Plus (CPC+) Initiative, which was announced today. CPC+ is the largest-ever initiative to transform and improve how primary care is delivered and paid for in America. This progressive comprehensive primary care model will be implemented in up to 20 regions and can accommodate up to 5,000 practices, encompassing more than 20,000 doctors and clinicians and the 25 million people they serve.

“The PCPCC has long advocated for this type of multi-payer evolution in health delivery and payment reform. Decades of research has shown that health care systems built on a strong foundation of comprehensive primary care lead to better care, smarter spending, and healthier people. The program announced today combines the power of comprehensive primary care with much needed payment reform.

 “The CPC+ is structured around multi-payer collaboration – one that aligns payment and performance measures across state, federal, and commercial payers in partnership with primary care providers. The research supports that these multi-payer efforts are positioned to scale and spread best practices to optimize primary care delivery for patients and families. The PCPCC’s Annual Patient-Centered Medical Home Evidence Report highlights 30 medical home evaluations that point to a clear trend in reducing health care costs and/or unnecessary utilization, such as emergency department (ED) visits, inpatient hospitalizations and hospital readmissions. Those with the most impressive cost and utilization outcomes were generally those that participated in multi-payer collaboratives.

“As described in the Annual Evidence Report, practices face several challenges when assuming the financial risk and accountability in a patient-centered medical home model of care. These challenges include: the need for adequate and predictable payment together with appropriate risk adjustment – especially when caring for high-cost, high-need patients; team-based care that integrates behavioral health and coordinates care across the medical neighborhood and community; interoperable electronic health records and population health management tools; other technology to support patients and practices – such as telehealth and mobile health applications; access to timely integrated data at the point of care, and authentic patient and family engagement in care transformation. CPC+ incorporates this learning with up-front investment to practices, payment based on the health needs/risk of their patients, a push for health information technology that benefits care delivery, and a focus on patient and family engagement.

“Given the variability in primary care practice readiness for delivery and payment reform, CPC+ is designed to meet primary care practices wherever they may be along the practice transformation continuum. CPC+ will allow practices to apply for one of two program tracks that is matched to their level of ‘practice readiness’ with increasing payment and care redesign expectations from Tracks 1 to 2. Track 1 is very similar to the existing Comprehensive Primary Care (CPC) initiative and targets practices that have the requisite infrastructure to deliver comprehensive primary care services. Track 2 is designed for more advanced practices that are already proficient in delivering these services but stand ready to offer additional supports for complex patients.

“The CPC+ initiative represents the future of health care. It encourages the type of comprehensive primary care that not only leads to more effective, efficient, and patient-centered care but also embraces value. It moves us a significant step forward in providing the necessary payment structures to enable primary care providers to operate as high functioning patient-centered medical homes – with clinicians and care teams that offer trusted healing relationships with patients and their families.”

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Editor's Note: To arrange an interview with Marci Nielsen, contact Amanda Holt, 202-640-1212, or amanda@pcpcc.org. We also invite you to access our online Primary Care Innovations and PCMH Map where we track these types of advanced primary care programs nationwide. You can view the CPC+ initiative listed on our map here.

About the PCPCC

Founded in 2006, the PCPCC is a not-for-profit membership organization dedicated to advancing an effective and efficient health care system built on a strong foundation of primary care and the patient-centered medical home (PCMH). The PCPCC achieves its mission through the work of its volunteer members, Stakeholder Centers, experts, and thought leaders focused on key issues of delivery reform, payment reform, patient engagement, and benefit design to drive health system transformation. For more information, or to become an executive member, visit www.pcpcc.org.

PCPCC Responds to CMS Request for Stakeholder Input on the Quality Measure Development Plan

March 2, 2016

On March 1, 2016 the PCPCC responded to the Centers for Medicare and Medicaid Services (CMS) request for stakeholder input on the Quality Measure Development Plan.

Overall, PCPCC supports the general framework for the Quality Measurement Development Plan (QMDP) as proposed, within the framework of CMS’ six Quality Strategy Goals. In particular, we agree with CMS' strategic approach to include multi-stakeholder groups to assist in generating creative solutions for use of measures across multiple payers and delivery systems, from both the private and public sectors. In our comments, the we provide additional input on the following sections of the Operational Requirements of the QMDP:

  1. Multi-payer Applicability of Measures
  2. Quality Domains and Priorities
  3. Care Coordination
  4. Patient and Caregiver Experience
  5. Population Health and Prevention
  6. Efficiency and cost reduction
  7. Applicability of Measures Across Healthcare Settings

PCPCC Submits Comments to the Senate Finance Committee's Bipartisan Chronic Care Working Group

January 26, 2016

On January 26th, 2016, the Patient-Centered Primary Care Collaborative responded to the Senate Finance Committee's Bipartisan Chronic Care Working Group Policy Options Document, which requested stakeholder input on various policy proposals aimed at improving outcomes for Medicare beneficiaries with multiple chronic conditions. The PCPCC weighed in on several policy proposals, including those related to behavioral health integration, quality measure development, and waiving beneficiary co-payment for chronic condition management. Please open the PDF below to access our full comment letter. 

Improving Patient-Centered Medical Home (PCMH) Recognition: Board-Endorsed Recommendations of the PCPCC Accreditation Work Group

November 30, 2015

The ideal attributes of the patient-centered medical home (PCMH) need a timely update. The concept appears to have different meaning to patients and consumers, health care providers, and payers/health plans. Likewise, the meaning (and purpose) of the current recognition/certification processes for PCMHs can be equally confusing. 

Thus the PCPCC Board of Directors and staff convened a select group of experts in patient-centered advanced primary care to help identify the opportunities and challenges of the current PCMH certification/recognition process, especially at it pertains to the public – patients, consumers, employees, and employers/health plans – as well as to primary care practices. To inform this effort, the PCPCC Accreditation Workgroup was formed in July 2015 and set out to:

•    Identify and analyze opportunities in the current PCMH certification/recognition marketplace, especially as it relates to meaningful and ongoing primary care practice transformation; i.e. identify the aspirations of the medical home model of care [with an eye toward the public];
•    Identify and analyze challenges, to include administrative burden, in the current PCMH certification/recognition marketplace; i.e. identify where there are needed improvements in the current approach and/or standards;
•    Provide the PCPCC Board of Directors with recommendations that can be used to help inform PCPCC advocacy efforts concerning public and private sector policies that promote the PCMH model of care (aspirational goal). 
Workgroup activities:

Then, on November 11, 2015, the co-chairs of the group presented draft recommendations to the PCPCC Board. After discussion (and minor editing) the Board of Directors enthusiastically approved the following recommendations:

PCPCC Comments on the Alternative Payment Model (APM) Framework Draft White Paper

November 20, 2015

On November 20th, 2015, the PCPCC submitted comments to the Alternative Payment Model (APM) Framework and Progress Tracking Work Group on their recently released Alternative Payment Model (APM) Framework Draft White Paper. Our complete response to the work group's request for stakeholder input can be found in the PDF attached below. Please contact Lisabeth Buelt at lisabeth@pcpcc.org with any questions or comments regarding this response.  

PCPCC Responds to CMS Request for Information on Alternative Payment Models and the Merit-based Incentive Payment System

November 17, 2015

On November 17th, the Patient-Centered Primary Care Collaborative (PCPCC) responded to the Center for Medicare and Medicaid Services Request for Information (RFI) regarding "Implementation of the Merit-Based Incentive Payment System, Promotion of Alternative Payment Models, and Incentive Payments for Participation in Eligible Alternative Payment Models". In the letter, the PCPCC advocates for measurement harmonization, describes the need for multiple pathways for practices to be recognized as "certified medical homes" under MACRA, and underscores the need to reevaluate the definition of "nominal risk." 

PCPCC submits comment letter to CMS on the 2016 Medicare Physician Fee Schedule proposed rule

September 8, 2015

On September 8th, 2015, the Patient-Centered Primary Care Collaborative (PCPCC) submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule for the 2016 Medicare Physician Fee Schedule. In the letter, the PCPCC advocates for the transition from volume-driven, fee-for-service payment toward a risk-adjusted comprehensive primary care payment. The PCPCC also submitted comments on several issues related to high-performing primary care including: care management, behavioral health, advance care planning, the Comprehensive Primary Care Initiative, and specific provisions within the Medicare Access and CHIP Reauthorization Act (MACRA).  

View the PCPCC's complete response in the PDF attachment. 

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