The comprehensive primary care plus (CPC+) program officially launched in January 2017, but CMS recently announced that it would be re-opening the application process and expanding the initiative in spring 2017, prompting renewed interest among primary care practices.
Because of the built-in financial support from CMS and private payors, the program represents an attractive opportunity for these practices to make a foray into value-based care. At the same time, the prospect of starting this multi-year transformation journey can be overwhelming, as we learned from the initial CPC program over the past five years.
As such, many providers are asking “What do I need to be doing today to be sure I succeed with CPC+?” This post addresses that question by identifying the three areas interested practices should focus on to prepare for the launch of the initiative.
IT Infrastructure and Reporting
Practices must have a certified EHR that meets the program’s care management and data reporting requirements, including to the ability to track quality metrics. The program requires practices to report data for the full 2017 calendar year. Practices should also inventory their IT systems and talk to their EHR vendors about the ability to stratify patients by risk and flag them for care management. If a practice’s technology platform doesn’t have this functionality, practice administrators should build their own reports from the EHR, rather than waiting to receive claims data from Medicare and private payors several months after the program begins. To ensure the highest-need patients are being targeted for care management, practices will eventually need to reconcile their lists with the data from CMS and other payors.
In addition to understanding and planning IT infrastructure and capabilities, practices should be outlining the activities and resources necessary for the initiative. For example, comprehensive primary care efforts typically require additional project management or care team members such as care managers, care coordinators, and patient navigators. Practices will be required to create preliminary financial forecasts at the beginning of the year and then review them at the end of the year, developing appropriate reconciliations thereafter. This forecasting exercise will also force practices to begin thinking through work flows and capabilities to support CPC+ and succeed under the program.
Understanding the Payment Model
The final ingredient for success is educating providers about the CPC+ payment model. Although practices will continue to bill traditional Medicare FFS codes, they may also receive additional care management fees, performance-based incentive payments, and comprehensive primary care payments. Some of these payments are paid prospectively, quarterly, or annually, but could be reconciled at the end of the year if practices do not meet certain thresholds or criteria.
Additionally, practices and providers must understand how the CPC+ initiative aligns with other CMS initiatives, including the chronic care management initiative and transitional care management initiative.1 An in-depth understanding will allow practices to more successfully execute the initiative, plan financially, and expand efforts with commercial payors.
The Bottom Line
At its core, the CPC+ initiative is about care model transformation, which is hard work that takes time. By focusing on preparations in these three key areas, participating practices will set themselves on the right path.
For any CPC+ participating beneficiaries, practices cannot bill and will not be paid for any CCM-related services, including CPT codes 99487, 99489, 99490, G0506, and G0507. However, practices can continue to bill and will be paid for TCM services.