Next steps with CPC+ and SIM alignment

Why would practices participate in the SIM and CPC+ initiatives? SIM experts address provider questions. The Colorado State Innovation Model (SIM) encourages Colorado practices to apply for the second cohort of SIM practices and Comprehensive Primary Care Plus (CPC+). The key is understanding the nuances of each program and how they complement each other, which is why SIM subject matter experts will share perspectives on each program in the coming weeks. The SIM team encourages practices to apply for both programs. Tara Smith, strategy and policy manager, Colorado State Innovation Model Question: How will CPC+ support behavioral health integration, and how does the alignment between SIM and CPC+ help support the integration of behavioral health and primary care? Answer: While the Centers for Medicare & Medicaid Services (CMS) has indicated that behavioral health integration will be a component of care management activities under CPC+, the available support to practices that select this focus in the program has not yet been defined. The CPC+ Request for Applications (V 3.1) notes that practices in Track 1 will build capabilities in behavioral health and develop skills to provide longitudinal, relationship care management and short term, goal-directed care management to better meet patient needs. Practices selected for Track 2 will be expected to provide more intensive care management for patients who have complex needs, including those with multiple chronic conditions (including behavioral health). To highlight the benefits of participating in SIM, we have outlined the behavioral health support that practices accepted into the SIM Cohort 2 will receive: 

A practice facilitator, to guide your practice improvement team in ongoing change and quality improvement activities;

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A Clinical Health Information Technology Advisor to assist in building practice data capacity along with technical assistance provided through highly qualified Practice Transformation Organizations and the University of Colorado;

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Access to a Regional Health Connector, who can connect your practice to relevant community and state resources;

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Participation payments of up to $5,000 for meeting key practice transformation requirements and monetary assistance in the form of small grants and payer support;

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Access to MGMA DataDive™, an online resource;

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The opportunity to apply for additional grants to fund advancements towards behavioral health integration through a Practice Transformation Fund, anticipated to disburse between $1.625 and $2.375 million in 2016; and

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Participation in twice-yearly Collaborative Learning Sessions;

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Opportunity to earn Maintenance of Certification and Continuing Medical Education credits.

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Next steps with CPC+ and SIM alignment

SIM’s package of practice transformation services is designed to help practices improve in and across multiple domains – including care delivery transformation, population health, and health information technology. The range and scope of SIM practice transformation support helps practices develop workflows and competencies in areas that might not be addressed in other initiatives. The SIM Office is talking with CMS about ways to align SIM and CPC+ operationally so practices benefit from participation in both programs without duplicating efforts or funds. SIM and CMS representatives agree that the interrelated goals and objectives of the two initiatives create natural synergies and create a true benefit for practices and providers who are committed to transforming their practices. Our emerging vision of alignment is one in which practice requirements in certain areas – including practice transformation support, learning collaborative offerings, and quality measure reporting – will be coordinated to reduce provider burden and preserve SIM’s focus on the integration of physical and behavioral health. We do not yet have a clear picture of what participation in both initiatives will look like at an operational level. However, the team is committed to working with CMS to create a pathway for practices seeking to pursue both opportunities and encourage SIM cohort 1 practices that are interested in applying to CPC+ to do so and continue to participate in SIM. We believe that the two initiatives are complementary in nature and help Colorado practices prepare for value-based reimbursement while ensuring that they integrate behavioral health and primary care to address all elements of patient health and wellness. Question: Which practices should apply to SIM and CPC+? Answer: SIM and CPC+ have specific eligibility and participation requirements. These criteria, which are summarized below, help ensure that primary care practices selected for SIM and CPC+ are ready, willing, and able to engage in practice transformation activi ties. SIM requirements from cohort 1 that will be finalized in the request for application: To be imum 1. 2. 3.

eligible to receive practice transformation support, practices must meet the following minqualifying criteria: Provide comprehensive primary care services. Be physically located in Colorado. Apply on an individual practice site basis. Health systems and multisite practices cannot submit a general application for multiple practice sites. 4. Demonstrate the ability to meet requirements in certain key program areas, including:  Leadership and engagement: Expressed support from clinical and administrative leadership at the practice site and, if applicable, the larger health care organization.  Fiscal: Experience with annual budgets and the ability and willingness to test different alternative payment models.  Practice transformation: Documented experience with team-based care, quality improvement, using data to make improvements and population management; expressed willingness to establish quality improvement team that meet regularly; and achieved

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Next steps with CPC+ and SIM alignment

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recognition as a patient-centered medical home or similar advanced primary care delivery model. Technology: Use an Electronic Health Record (EHR); achieved Meaningful Use (MU) Stage 1 or higher attestation or meet key elements of MU criteria; and expressed commitment to reporting SIM clinical quality measures on a quarterly basis.

All primary care practices in Colorado, including federally-qualified health centers, rural health centers, and practices participating in Medicare Shared Savings Programs or Medicare Accountable Care Organization models, that meet these criteria are encouraged to apply for SIM. CPC+ A comprehensive overview of CPC+ application information is available from the Centers for Medicare & Medicaid Innovation (CMMI) website and includes some information about payment elements. The following summary should be used as a basic introduction. To participate in CPC+, practices must have multi-payer support, certified EHR technology (CEHRT), and other infrastructural capabilities (summarized below). Practices applying for Track 2 must demonstrate additional clinical capabilities to deliver comprehensive primar y care. 

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Track 1 Practice structure and ownership information, including number of practice sites and practitioners in the organization, practice tax identification numbers (TINs), participation in Medicare programs and demonstrations, information and national provider identifier (NPIs) for each primary care practitioner in a practice Use of CEHRT Sufficient revenue generated by Medicare and CPC+ payer partners Existing care delivery activities must include: assigning patients to provider panel, providing 24/7 access for patients, and supporting quality improvement activities

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Track 2 Practice structure and ownership information, including number of practice sites and practitioners in the organization, practice tax identification numbers (TINs), participation in Medicare programs and demonstrations, information and national provider identifier (NPIs) for each primary care practitioner in the practice Use of CEHRT Sufficient revenue generated by Medicare and CPC+ payer partners Existing care delivery activities must include: assigning patients to provider panel, providing 24/7 access for patients, and supporting quality improvement activities, while also developing and recording care plans, following up with patients after emergency department or hospital discharge, and implementing a process to link patients to community-based resources Letter of support from health information technology (IT) vendor that outlines a vendor’s commitment to support the practice in optimizing health IT.

Next steps with CPC+ and SIM alignment

CPC+ has additional restrictions on the types of practices and providers that are eligible to participate. As of Aug. 1, CMS has made the following determinations regarding eligibility: Practices that can participate in CPC+:  Practices participating in SIM  Hospital-owned practices  Practices in independent practice associations (IPAs)  Practices participating in commercial accountable care organizations (ACOs) or commercial clinically-integrated networks (CIN)  Practices participating in the Medicare Shared Savings Program* - up to 1,500 practices across all CPC+ regions  Pediatric practices with the following caveat from CMS: “…It is unlikely that pediatric practices will be eligible to participate due to the CPC+ requirement that primary care practices must have at least 150 attributed Medicare fee for service beneficiaries to be eligible for this model.” Learn more in the frequently-asked-questions section of the website. Practices that cannot participate in CPC+:  Federally-qualified health centers  Rural health centers  Concierge primary care practices that charge patients retainer fee s  Practices participating in the Medicare ACO Investment Model, Next Generation ACO Model, and some other shared savings programs For additional information about the CPC+ application, providers are encouraged to visit the CMMI website.

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