CMS Seeks Public Input On Advanced Primary Care Model Concepts

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On February 13, 2015, CMS published a Request for Information (RFI) seeking input on the design of the next generation of advanced primary care models.  Comments on the RFI are due on March 16, 2015. 

According to the RFI, “[n]ext generation model(s) for advanced primary care would seek to improve further the delivery of patient-centered care and population health and would align with [HHS]’s goal to increase the use of alternative payment models.”  General topics of interest to CMS include, but are not limited to: (1) increased comprehensiveness of, and patient continuity with, primary care; (2) care of patients with complex needs; (3) closer connections between primary care and other clinical care, and community-based services; (4) moving from encounter-based payments towards population-based payments; (5) advanced primary care within accountable care organizations; and (6) use of health information technology to support advanced primary care.   

One area of particular interest to CMS is moving from a system of encounter-based payments for primary care services to population-based payments (PBPs) (i.e., payments based on a practice’s population of beneficiaries).  CMS explained that PBPs could cover two components: (1) severity-adjusted, non-visit based care management services, and (2) a portion or all of the expected, severity-adjusted fee-for-service payment for a basket of services provided in primary care.  CMS seeks comments on this description of PBPs, such as the impact on the delivery of advanced primary care and primary care practices’ readiness to take on such arrangements.

Comments on the RFI are due on March 16, 2015.  The RFI is available by clicking here.

Reporter, Linda Lin, Atlanta, +1 404 572 3566, llin@kslaw.com.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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