PCPCC's Comments: Direct Provider Contracting Models - Request for Information

The Patient-Centered Primary Care Collaborative (PCPCC) appreciates this opportunity to provide input on new models with the potential to enhance the patient-clinician relationship and allow providers to innovate to enhance the quality of care for Medicare, Medicaid, and Children’s Health Insurance Program (CHIP) beneficiaries.  PCPCC is pleased to offer this feedback to the Request for Information, but given the expansive nature of this request, strongly encourages CMS to plan another opportunity for input prior to implementing such a model. 

PCPCC Key Points 
 
PCPCC is pleased to see CMS focused on the challenge of empowering primary care in a value-based environment. We believe there is potential for innovation that strengthens the patient-clinician relationship, provided it is done in a deliberate manner with significant additional guidance. Our key points include:  
 
• CMS must further develop its thinking in this area, focusing this effort on unique opportunities to affect change, then create another opportunity for more detailed feedback and guidance.

• Strong beneficiary protections, dependent on how the model is structured, will be needed – including strong risk adjustment and quality measurement, which needs further investment.   While direct contracting offers new opportunities to engage and empower patients and clinicians, it also comes with significant risks.   

• While PCPCC supports new efforts to engage more providers in value-based care, CMS should avoid changes that might undermine existing programs that are already creating change due to limitations in CMMI’s staff and funding capacity. 
 
 
• Direct contracting in primary care should be an opportunity to increase funding for, and capability of, primary care to address health needs both within and outside of the practice. 

• Cost containment should not be the primary emphasis of a new model, as it will lead to the wrong priorities when designing and launching a model.  Improving quality though a stronger patient-clinician relationship must be the goal.  A primary carefocused model may create cost savings for the health system, but it can take years for this type of transformation to take hold and the savings will not materialize within the scope of a primary care contract.