CMMI Pulls Seriously Ill Component of Primary Care First Model

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Recently, the Center for Medicare and Medicaid Innovation (CMMI) withdrew the seriously ill population component of the Primary Care First model, based on concerns over whether it would get enough beneficiaries to participate. The withdraw follows the postponement that the Center opted to “freeze” in the spring during its larger review of all models.

According to an interview with CMMI Director Liz Fowler, “we cannot get enough beneficiaries to participate in the way we anticipated.”

Under the Primary Care First model, there were two components: a general one and one focused on seriously ill beneficiaries without a primary care doctor/effective care coordination. The general component allows advanced primary care practices to take on financial risk and receive performance-based payments while the seriously ill population component asked physicians to determine the social needs of identified patients and address other social determinants of health, creating a healthcare and wellness plan. Under the model, practices could opt to apply to both components or choose just one.

However, CMMI ran into difficulties with creating a HIPAA-compliant outreach method to find seriously ill population beneficiaries. Initially, CMMI planned to connect providers to these beneficiaries and have the providers do the outreach, “but if those providers don’t have a relationship with the beneficiary, that is where the privacy concerns come in,” Fowler said.

The second idea was for CMMI to perform the outreach to avoid privacy concerns. However, CMMI again raised concerns about the outreach, this time worried about fraudulent outreach – “We were careful in designing the approach that it would look official,” Fowler said. “We didn’t want to open the door to the perception of any malfeasance or bad actors. We just couldn’t figure out a way to make that work.”

While CMMI did previously accept applications for the seriously ill component of the model, since it never actually launched, any applications that were submitted for both the seriously ill component and the general component will remain in the general component. However, if a provider applied just for seriously ill, they will not be considered, nor will they be able to apply for the general component.

While CMMI has withdrawn the model for now, they remain open to it in the future if they can find a way to make it work. Last fall, CMMI also released a strategic refresh that focused on health equity in all models going forward. In the refresh, CMMI committed to five strategic objectives and measuring progress against defined metrics, resulting in revisions being made to existing models and a “more streamlined portfolio,” resulting in a “broad system transformation” as CMMI enters into its second decade.

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