Last week, CMS released the final list of participants in Round 1 of the Comprehensive Primary Care Plus (CPC+) program. I'd like to congratulate the nearly 3,000 practices selected to participate!
CPC+ is a five-year program that involves 57 payers and 2,893 practices in 14 regions. For the practices selected, participating means major changes to practice patterns as well as considerable funding to advance population health management.
This funding is significant, because some of the most common reasons organizations fail in their pursuit of care transformation goals are limited funding, treating value-based care as a special project, and competing financial incentives.
I have the privilege of leading a consulting team that has been nationally recognized by both KLAS and Kennedy for helping our members achieve some remarkable outcomes. We have partnered with well over 100 provider organizations to build or advance their value-based care capabilities in numerous accountable payment environments. Even though CPC+ is a new program, there are a number of best practices that I can offer for consideration.
Here are five best practice initiatives you can apply locally—whether your organization is participating in Round 1, considering future participation, or just hoping CPC+ will bolster your value-based care and accountable payment contracting opportunities.
#1: Focus on provider engagement, education, and participation
Whether it is CPC+, MACRA, MSSP, or another accountable payment initiative, success ultimately lies with engaging providers and most likely changing their behavior. So executives at participating organizations need to work with providers and practice staff to ensure they not only understand the CPC+ requirements, but are engaged with the goals and strategies that led the organization to participate in the first place. Candidly, the best practice approach is to include physician participation in governance and set up an ongoing process of physician engagement and education.
#2: Align physician compensation with strategic goals
To join Track 2 of CPC+, providers had to submit a written commitment to compensate their CPC+ providers in a way that "rewards quality of care, not just patient visit volume, and is consistent with" partial capitation.
We're working with a health system that now has several practices selected for CPC+ Track 2; however, our value-based care model design work with them also includes building a regional Clinically Integrated Network (CIN) and a Hospital Efficiency Improvement Program. So they've decided to take CPC+'s primary care compensation mandate as an opportunity to redesign compensation across their entire physician enterprise, and incentivize goals associated with optimal care transformation across the full continuum.
This is an opportunity for any medical group or health system, regardless of participation in CPC+, to create a new physician incentive model that aligns to its own quality and care transformation goals.
#3: Bolster clinical documentation improvement efforts
Many have learned the hard way under Medicare's shared savings contracts how full and accurate risk adjustment can make or break performance. Like shared savings, reimbursement under CPC+ is closely tied to risk adjustment, and participants will only get full credit for their patients' acuity if they improve documentation accuracy.
But in a more direct way than most programs, CPC+ actually provides differential care management payments based on the Hierarchical Condition Category (HCC) codes for patients. Under Track 2, practices receive a yearly fee per patient—$108 for patients with risk scores in the lowest quartile, and up to $1,200 for patients with risk scores in the top decile.
There's no question of the value of improving HCC capture and documentation accuracy, and it doesn't have to be as labor-intensive as one might think. We partnered with a 1,200 physician medical group in the Midwest that realized improvements in its HCC capture rate from 65% to 80%—a $4 million dollar benefit within four weeks—by embedding real-time decision support analytics into their EHR.
#4: Think systemically on care management resource decisions
CPC+ dollars must be earmarked for CPC+ practices, but their care management resources can be shared across multiple dimensions, including post-acute, ED, inpatient, and other medical group practices. With payment no longer tied to fee-for-service, we're seeing innovative ways to leverage staff at the top of their license. These include pharmacists in the ambulatory setting, nurse practitioners doing home visits, and diabetes educators across the community, to name just a few.
To make the most of care management investments, organizations involved in CPC+ need a care management strategy and staffing plan that considers the right number and types of care managers to hire, and where they should be placed to maximize their impact. We also recommend having some practices in the medical group or CIN increase their specialization—perhaps by way of an extensivist model or ambulatory ICU—to better support the network's highest risk patients.
#5: Focus on improving access
Although expanding patient access is critically important whether you're primarily fee-for-service or fee-for-value in orientation, it's especially important for CPC+ participants.
Whereas improving clinical documentation accuracy can ensure the highest possible care management payment amounts, improving access can enable practices to actually increase panel size attribution—and thereby the number of care management payments coming to the practice. If patients can't get in to see a provider, it's difficult to manage their care and improve outcomes. And it's impossible to get paid for taking care of them.
A special consideration for practices not participating in CPC+ yet
As I mentioned above, the most common reasons we see organizations fail in their care transformation efforts are limited funding and competing financial and/or organizational incentives. CPC+ helps alleviate that challenge, because participating practices now have a commitment from commercial and government payers to provide the fees and incentives mentioned. These payments will represent at the very least 40% of the participating practice's revenue. To give you a sense of scale, MSSP has paid out $1.3B since it began in 2012, and we estimate CPC+ will pay out $1.1B to providers in its first year alone.
If you're not yet participating, we recommend using CPC+ as a lever to talk to your payers. CMS is already soliciting a second round of applications for regions that weren't included in Round 1—with payer proposals to be accepted as early as mid-February, and a provider application period as early as late spring. Encourage your payers to apply! Additionally, now that 57 payers have a "CPC+" model in place, consider requesting a "CPC+-like" contract that provides outcomes-based incentives.
Access to Care,