28 May CMS Geographic Population-Based Payment Model RFI Response
In this letter, the Task Force responds to the Center for Medicare and Medicaid Services’ Direct Contracting – Geographic Population-Based Payment (PBP) model Request for Information (RFI). Our perspectives shared in this letter come from Task Force members viewing themselves as potential Direct Contracting Entities (DCEs) as well as partners that would collaborate with DCEs.
Task Force Response Summary
- Reactions to the Direct Contracting Model Announcement. The Direct Contracting – Professional and Global PBP models offer a welcome opportunity for organizations to leverage their experience with managing population health risk in the commercial market. CMS should provide expectations for how primary care is to be transformed in addition to establishing enhanced primary care capitation payments.
- Design and Operational Considerations for Geographic Population Based-Payment model. The Geographic PBP raises several interesting and challenging design considerations; in particular, the Task Force considered how DCEs would interact with existing APMs given the proposed broad scope of the proposed Geographic PBP model. Our comments offered herein reflect a desire for continued collaboration to help CMS to best operationalize this model in a way that leverages rather than replaces the growing number of Medicare alternative payment model arrangements that are showing promising results.
Response submitted on May 28, 2019