Comprehensive Primary Care Plus (CPC+) 2017 program requirements overview

In November, practices who applied for the Comprehensive Primary Care Plus (CPC+) program for 2017 found out whether they were selected to participate in the coming year. In mid-December, CMS announced that the model would re-open along with the Next Generation ACO model in January and February 2017. The new practices and payers accepted into the CPC+ program in this second round of applications will begin participating in the model in the 2018 performance year. Both CPC+ and the Next Generation ACO model are Advanced Alternative Payment Models under the Quality Payment Program, which has significant benefits for participants.

For those providers who were recently accepted into the CPC+ program, and for those who may be considering applying in 2017 for the 2018 performance year, we have put together a summary of requirements for the program pulled from across the available CMS resources, including:

  • Overview of CPC+ payment benefits
  • CPC+ IT requirements for 2017

You can also find a list of CPC+ quality measures for 2017 here.

Overview of CPC+ payment benefits

There are two tracks of the CPC+ program, with different levels of risk and potential upside. Here is a summary of the payments that will be made in each track under the CPC+ program:

  • Care Management Fee: Practices in both tracks will receive a non-visit-based Care Management Fee paid per beneficiary per month. The amount is risk-adjusted for each practice to account for the intensity of care management services required for the practice’s population and will be paid on a quarterly basis.
  • Performance-based incentive payment: CPC+ will prospectively pay and retrospectively reconcile a performance-based incentive based on how well the practice performs on patient experience measures, clinical quality measures, and utilization measures (see below for the clinical quality measure set for 2017 CPC+).
  • Payment under the Medicare Physician Fee Schedule: Track 1 will continue to bill and receive payment from Medicare FFS as usual. Track 2 practices will also continue to bill as usual, but the FFS payment will be reduced to account for CMS shifting a portion of Medicare FFS payments into Comprehensive Primary Care Payments (CPCP), which will be paid in a lump sum on a quarterly basis absent a claim. Given CMS’s expectation that Track 2 practices will increase the comprehensiveness of care delivered, the CPCP amounts will be larger than the FFS payment amounts they replace.
 Track Care Management Fees (CMF), per beneficiary per month Performance-based incentive payments Visit- and non-visit-based payments
 1  $15 average Utilization and Quality/Experience Components CMF + FFS
 2 $28 average; $100 for complex Utilization and Quality/Experience Components CMF + ↓ FFS + ↑ CPCP

CPC+ information technology (IT) requirements

All CPC+ practices will be required to meet a minimum level of Certified Health Information Technology (HIT) adoption, and Track 2 has additional HIT requirements.

All CPC+ practices in 2017 will be required to:

  • Adopt, at a minimum, the certified health IT needed to meet the certified EHR technology (CEHRT) definition required by the Medicare EHR Incentive program
  • Adopt health IT meeting 2015 Edition certification criteria for eCQM reporting for all of the electronic clinical quality measures in the CPC+ measure set, using the latest eCQM specifications contained in the 2016 annual update
  • Adopt technology which allows filtering of data by at least practice site location and TIN/NPI

Track 2 practices in 2017 will be additionally required to:

  • Adopt health IT certified to the 2015 Edition “Care Plan” criterion
  • Adopt health IT certified to the 2015 Edition “Social, Behavioral and Psychological Data” criterion

CMS is also requiring that Track 2 practices work with HIT vendors to achieve the following technical enhancements. CMS will not prescribe how the health IT enhancement is accomplished, only that the health IT solution meets the CPC+ objective for use of the health IT by the CPC+ practice site team. Track 2 practices will need to be able to:

  • Risk-stratify practice site patient population; identify and flag “Patients with Complex Needs”
  • Produce and display eCQM results at the practice level to support continuous feedback
  • Systematically assess patients’ psychosocial needs and inventory resources and supports to meet those needs
  • Document and track patient-reported outcomes
  • Empanel patients to the practice site care team
  • Establish a patient focused care plan to guide care management

Stay informed about updates related to CPC+ participation with the Able Health newsletter!

Further reading:
Submitting MIPS through the new CMS website: what it can and can’t do
Downloadable Tool! The 2017 MIPS Submission Checklist

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