What happened

CMS announced two primary care models within the Centers for Medicare and Medicaid Innovation (CMMI) will be shut down by the end of 2025, earlier than originally scheduled:

• The Primary Care First (PCF) model, which was designed to improve advanced primary care, particularly for patients who do not routinely see primary care providers. Launched in 2021, the original end date for PCF was 2026.
• The Making Care Primary (MCP) model, which was designed to improve coordination and care management between primary care providers, specialists, and community resources. Launched in 2024, the original end date for MCP was 2034.

Though some leaders question what these models ending early means for value-based care (VBC) in general, this does not mean CMS is abandoning VBC in primary care as a core strategy. CMS specifically said: “The early termination of Primary Care First and Making Care Primary does not signal a retreat from the Center’s support of primary care providers, but rather a need to focus on different approaches that are consistent with the CMS Innovation Center’s statutory mandate and produce savings.”¹ Despite the models’ early cessation, VBC is here to stay.

Why this matters

The PCF and MCP models boosted primary care providers’ revenue, enabling them to make population health investments with limited downside risks. Without these models, participants will see significant reductions in revenue — an estimated 36% for Making Care Primary participants² and 33% for Primary Care First participants.³

Making Care Primary provided up-front payments for care management infrastructure without penalties for poor performance. Primary Care First guaranteed population-based payments with potential bonuses for high quality. Even when participants faced penalties from high or out-of-network utilization, they still came out ahead compared to fee-fer-service rates due to the large population-based payments. Without the financial support these models provided, it will be harder for primary care-focused organizations to succeed in VBC — and maybe even stay financially solvent or independent.

What comes next

The next step for participants is to decide which risk model – if any – would be right for them. Click "see risk model options" below to view a table of the main choices.^4,5

How to decide

Primary care providers should consider four questions when deciding what to do next.

The good news? MSSP A/B and MSSP Enhanced offer higher revenue, on average, than Primary Care First. And with increasing risk comes a higher upper limit to that revenue. The upper limit for MSSP Enhanced is nearly three times the upper limit of Primary Care First, and the upper limit for MSSP A/B is nearly double the limit for PCF.  A provider organization pursuing two-sided risk in Medicare Advantage (MA) would see a similar trend. The bad news? All have greater accountability and a lower floor.

Can you evaluate the tax identification numbers (TINs) in your network? Is your risk adjustment program established and performing well? Can you target the right populations for your total cost of care strategies? Those are useful capabilities. Don’t underestimate them.

In the Primary Care First and Making Care Primary models, provider organizations made key investments in technologies, analytics, care management, and risk-adjustment operations. A return to fee-for-service would mean taking a big step back from that infrastructure. Organizations that have already invested in primary care models need to decide whether to capitalize on these investments or consider them as losses.

The actual work of changing financial and clinical models in the complex healthcare industry is difficult. Organizations need agreed-upon objectives and leaders (especially CEO and CFO) who are all on the same page. This leadership alignment is the foundation for successfully synchronizing the clinical and financial transformation.

Organizations that do this right take on enough risk to learn and build momentum without compromising themselves or ending up in pilot purgatory. But, they don’t take on so much that they are the first through the wall — after all, data from the Medicare Shared Savings Program shows us that organizations with more experience in VBC typically do better.

There is no perfect calculation for moving into increased levels of at-risk payments. But we know that when VBC becomes a reality in a market, it happens fast. We recommend looking at:

• Current risk adoption: You can't afford to be the laggard but you're just as likely to make a mistake as an early adopter. An immature market in VBC can present a key opportunity in MSSP. Less mature VBC markets have easier MSSP benchmarks, making it easier to achieve early success.
• MA penetration: Evaluate the balance between MA and traditional Medicare beneficiaries in your market and analyze trends over time. As any actuary would tell you, a large, stable, or growing population is critical for effectively spreading financial risk. Ensure your population size is sufficient before assuming risk.
• Health plan partners: A risk arrangement in MA requires the plan and provider to formally align incentives related to quality and cost goals. Do you have a viable health plan partnership? You’ll need it.

One no-brainer: Don’t miss out on Advanced Primary Care Management (APCM) codes

For provider organizations participating in risk arrangements, there is one no-brainer: APCM codes.

CMS introduced APCM codes in the 2025 Medicare Physician Fee Schedule (before announcing the early end of Primary Care First and Making Care Primary). APCM codes offer a streamlined approach to care management billing with simpler time requirements and availability to all Medicare patients, albeit with a 10% lower reimbursement rate compared to the fee-for-service care management codes.

APCM codes provide flexibility and efficiency by shifting over 50 codes to three monthly bundle options that don't have the same time constraints. This allows practices to leverage their population health and care management infrastructure investments from Primary Care First and Making Care Primary. But while these codes offer easier short-term implementation, they make sense only when paired with a two-sided risk model that incentivizes care management at scale.

What participants should do now

There’s a lot happening in healthcare right now. This is an important moment to get your leadership team aligned on the right next step for your organization. In our extensive research and engagements with providers, we’ve found the key to success in these VBC primary care models is leadership alignment. It’s the foundation for fully synchronizing clinical and financial transformation.

If you need help evaluating your options, get in touch.