The Task Force Provides Feedback to CMMI on the Direct Contracting Model Global and Professional Track

The Health Care Transformation Task Force (HCTTF or Task Force) is writing to convey our member feedback on opportunities for improving the design and implementation of the Direct Contracting Model’s (DC model) Global and Professional tracks.

HCTTF understands CMMI’s decision to pause the Direct Contracting model and the design issues that precipitated that pause. We believe that now is the time to modify the model and to create an offering that will be attractive to experienced ACOs, including those who have participated in the Next Generation ACO model. This letter details several recommendations for modifications to the DC Model’s Global and Professional tracks intended to ensure that it focuses on advancing care transformation, supporting connections between patients and providers, and improving population health. Making the modifications recommended below will improve buy-in to the model and create a stronger future for total cost of care delivery models.

Task Force Response Summary

Direct Contracting Model Specific Comments:

  1. Model Overlap and Transitions: CMS should align application requirements and timelines for models targeting similar participant types, in this case Direct Contracting and the Medicare Shared Savings Program. CMS should also prioritize providing additional clarity on the status of the DC Model’s Geographic track currently under review so that organizations considering the DC model can take make fully informed participation decisions. In the interest of expanding participation, CMS should offer the option to suspend capitated payments to the second cohort (as was done for the first DC model cohort during year 1) and extend this option for the duration of the model.
  2. Direct Contracting Entity Types and Supporting APM Adoption: HCTTF encourages CMS to redesign this aspect of the DC model to allow for alignment between Standard and High Needs DCEs under a single TIN using a blended capitation rate based on beneficiary level risk adjustment. Given the potential for APMs to improve quality and efficiency, and the fact that providers without APM experience disproportionately serve under resourced communities, we urge CMS to evaluate and implement strategies to support providers as they gain the necessary experience and develop the capacity to manage risk.
  3. Clarity on DCE Audit and Compliance Liability: CMS should clarify the DCE audit and compliance responsibilities for providers and their responsibilities related to their participating providers’ billing practices.
  4. Financial Methodology: 
    • CMS should enhance the shared savings arrangement to provide stronger incentives for the Professional Track.
    • CMMI should reconsider the DC model benchmarking approach and align the methodology for both voluntary and claims-based alignment across the standard and new entrant DCE types.
    • We encourage CMS to consider modifying the discount by applying a flat rate of 2 percent across all years of the model and research additional flexibilities that could be used to support the participation of providers working with under resourced communities. Additionally, we believe that CMS should acknowledge the historical spending reductions of Next Generation ACO participants by removing the discount for the first two years of the model.
    • To truly invest in primary care, CMS should reconsider the design of the enhanced capitation feature of the Primary Care Capitation option by allowing DCEs the option to extend repayment over more than one model year.
    • We encourage CMS to reconsider the decision to eliminate the alternative methodology option and accept proposals from DCEs.
  5. Quality Measures: CMS should consider a lower withhold amount of 2.5 percent which we believe would still provide sufficient incentive to meet quality goals and provide details on the anticipated CI/SEP and performance benchmarks necessary to earn back the withhold amounts to assist organizations in making informed.
  6. Risk Adjustment: We urge CMS to clarify the risk adjustment strategy. Additionally, CMS should create a zero percent floor for risk adjustment to reduce the incentive for participants to make large investments in HCC documentation programs solely for the purpose of pursuing favorable comparative risk coding.
  7. Retention Penalty: We recommend that CMS eliminate the retention penalty. If a full elimination of this penalty is not feasible, we urge CMS to consider waiving the penalty for organizations that decide to leave the DC model to participate in another CMS advanced risk APM.

Read the Full Letter