- The Center for Medicare & Medicaid Services unveiled a new advanced primary care model which has certified EHR use listed as a core element of its two tracks.
The Comprehensive Primary Care Plus (CPC+) model is slated for implementation in 20 regions and can include as many as 5000 physician practices in the pursuit of improving care delivery.
“Strengthening primary care is critical to an effective health care system,” CMS Deputy Administrator and CMO Patrick Conway, MD, said in an official statement. “By supporting primary care doctors and clinicians to spend time with patients, serve patients’ needs outside of the office visit, and better coordinate care with specialists we can continue to build a health care system that results in healthier people and smarter spending of our health care dollars. The Comprehensive Primary Care Plus model represents the future of health care that we’re striving towards.”
Beginning in 2017, the CPC+ makes available two tracks for primary care medical homes to earn incentives by meeting incrementally advanced program requirements. CMS describes the two tracks as follows:
In Track 1, CMS will pay practices a monthly care management fee in addition to the fee-for-service payments under the Medicare Physician Fee Schedule for activities. In Track 2, practices will also receive a monthly care management fee and, instead of full Medicare fee-for-service payments for Evaluation and Management services, will receive a hybrid of reduced Medicare fee-for-service payments and up-front comprehensive primary care payments for those services. This hybrid payment design will allow greater flexibility in how practices deliver care outside of the traditional face-to-face encounter.
Integral to both tracks (and more so for the second track) is certified EHR use. Unlike Track 1, the second requires eligible providers to work with their health IT vendors beginning with the application itself:
"As part of the application process for Track 2, practices will be asked to submit a letter of support from their health IT vendor(s) that outlines the vendor’s commitment to support the practice in optimizing health IT," an official list of frequently asked questions states. "Following the selection of practices for the model, vendors will complete a [Memorandum of Understanding] MOU with CMS that reiterates their willingness to work together with CPC+ practice participants to develop the required health IT capabilities."
Common to both tracks are two health IT-related components: the use of certified EHR technology (CEHRT) and reporting electronic clinical quality measures (CQMs).
For the former, participating practices must demonstrate the adoption of certified health IT by Jan. 1, 2018.
By the beginning of 2017, these practices must demonstrate the adoption of certified eCQMs listed in the CPC+ measure set. By the same date, practices must meet an eCQM certification requirement for filtering data by practice site and practice/provider identifiers (e.g., TIN, NPI).
Unique to Track 2 and required to be in place by Jan. 1, 2019, CPC+ participants must adopt two capabilities — Care Plan and Social, Behavioral and Psychological Data under the 2015 Edition Health Certification criteria.
"CPC+ offers opportunities to align multi-payer payment reform and health IT support with practice transformation. Primary care practices require advanced health IT capabilities that are not always available in current systems or required by ONC certification," an official CPC+ fact sheet reads.
As a result, CPC+ participants will have to rely on CMS and ONC to collaborate with EHR vendors to support providers in this track.
The first eCQM performance period runs the full 2017 calendar year, followed by the first eCQM submission period beginning on Jan. 1, 2018.