Curbside Consult with Dr. Jayne 10/28/19

CMS has finally delivered its Request for Application for the Primary Care First program, which had long been promised to arrive in summer of 2019.

Everyone loves an endless summer, except for the people who have been waiting a really long time for the application for a program that was to start in January 2020. Now, applications are due by January 22, 2020 for a program that won’t begin until January 2021. CMS also promises that “in the coming week” it will release a “Statement of Interest” form for prospective payer partners who want to declare their interest in a non-binding fashion. A formal solicitation process for payer partners will then run from December 9 through March 13, 2020. CMS notes that “this timeline will allow payers to clearly assess where there is likely to be high practice participation in Primary Care First, and make an informed decision about regions in which to develop their own aligned approaches as payer partners.”

Continuing with some vague deadlines, CMS notes that the selection process for practices and payers will take place in “Winter-Spring 2020,” which gives them a fairly long runway since summer apparently stretches to October 24 in their universe.

The CMS FAQ document had some interesting tidbits, for those of you who haven’t had a chance to dive into the documentation yet:

• If more than 3,000 practices apply and meet the eligibility criteria, CMS will use a lottery system to select final participants.
• A second round of applications will occur for practices that are participating in the Comprehensive Primary Care Plus (CPC+) program, to begin participation in Primary Care First starting in January 2022.
• Neither Federally Qualified Health Centers or Rural Health Centers are eligible to participate. CMS states this is because the program is designed to test payment reform for traditional fee-for-service payments, where the excluded centers bill under different but distinct rules.
• Participants will have to comply with interoperability requirements that will be spelled out in the Participation Agreement, which is not yet available for review.
• CMS “anticipates that Primary Care First will qualify as an Advanced APM for all give years of the model test.” I’m not sure why they can’t put their nickel down at this point and declare it. I find the “anticipates” language bothersome.
• CMS will be using a modified CAHPS (Consumer Assessment of Healthcare Providers and Systems) survey “to allow for increased response rate and ease of use among beneficiaries.”
• CMS will allow practices to reduce or waive the applicable co-insurance for the flat primary care visit fee, but practices are responsible for assuming these costs. Practices can determine which patients might benefit most from this, such as patients with frequent emergency department visits or hospital admissions. Practices will have to submit an implementation plan for this at a later date.
• Practices can offer other “beneficiary enhancements,” such as transportation to the primary care provider or other follow-up services. Patients can also receive access to remote monitoring technology or nutrition programs such as Weight Watchers. These will be detailed in the Participation Agreement, which again we haven’t seen.
• Additional guidance regarding telehealth will be provided at a later date.

I began to dig into the 102-page Request for Applications document and immediately began to regret it. There are seven possible levels of performance for regional performance bonuses dependent on the practices’ performance relative to a regional reference group. There are also tiers for the Continuous Improvement bonus.

When I reached the part about “Quality Gateways,” which practices have to meet in Year 1 to receive a bonus in Year 2, my eyes began to cross. My vision cleared up, though, when I saw that participants must agree to participate in CMS efforts to evaluate the model, which may include everything from surveys and interviews to site visits and other unspecified activities. Everyone loves agreeing to more site visits, and the part about “unspecified activities” certainly leaves room for uncertainty.

I was glad to see that the appendix does have all of the application questions listed out, since the application itself requires a login. That at least allows practices to make sure they have all their information gathered before they try to key it all in.

At this point in the game, I doubt any of my current practice clients will want to participate, but if any do, I’ll be referring them out to some consulting colleagues who are more specialized in this area than I will ever be. The devil is definitely going to be in the details for practices that go this route, and only they will be able to truly determine whether the proverbial juice is worth the squeeze. My state isn’t one of the ones that has been selected for the program, so I won’t be hearing about it in the physician lounge, that’s for sure. I do have enough colleagues around the country, though, and I hope at least one of them bites so I can share their experience with our HIStalk readers.

Having to wade through all the Primary Care First documents was enough to make me grateful to have back-to-back clinical shifts scheduled. Unfortunately, I saw my first vaping casualty,  a teenage patient whose lung collapsed after he decided to celebrate a recent academic event with some vaping in the high school parking lot. Luckily, he was in the car with a friend who saw him begin to go into distress and brought him for attention right away. The patient went from being reasonably conversant to beginning to turn blue over the course of a few minutes while we were waiting for EMS to arrive.

It was just another day at the office for our team of in-house paramedics, but based on the level of terror his friend experienced ,I doubt either of them will be vaping much in the near future. Due to the acute timeline of the incident, the patient’s parents didn’t arrive at our office until we had already bundled him into the ambulance and sent him on his way. That’s got to be just about one of the worst feelings a parent can have.

The rest of the weekend was largely uneventful, for which I’m grateful.

How did you spend your weekend? Leave a comment or email me.

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