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AAMC Submits Comments to CMS on Direct Provider Contracting Request for Information

May 30, 2018

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Gayle Lee, Director, Physician Payment & Quality

The AAMC May 25 submitted comments in response to the Centers for Medicare and Medicaid Services’ (CMS) Request for Information on creating a new direct provider contracting model demonstration in Medicare, Medicare Advantage, and Medicaid.

Under the model, CMS could contract directly with participating practices, such as primary care practices and larger multi-specialty groups, to establish the practice as the main source of care for services ranging from solely primary care to a wide range of professional services for beneficiaries that voluntarily elect to enroll with the practice. CMS could pay the practices a fixed per beneficiary per month payment (PBPM) and practices could have the opportunity to earn performance-based incentives.

In its comments, the AAMC recommends that CMS:

  • Maximize flexibility and minimize burden;
  • Create a gradual transition to downside risk and a cap for “catastrophic cases;”
  • Continue to allocate resources to existing models (e.g. accountable care organizations (ACOs) and bundled payments for care improvement) in addition to any new models;
  • Incorporate direct provider contracting into existing models, such as ACOs;
  • Include appropriate risk adjustment for patient complexity and sociodemographic status;
  • Expand opportunities to participate in advanced alternative payment models; and
  • Support investments in primary care.
     

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