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Deadline Arrives to Express Interest in CMS Direct Contracting Model

Analysis  |  By Steven Porter  
   August 05, 2019

After a delay, the deadline marks a moment of truth for a CMS payment model that some have heralded as potentially transformative.

Organizations may formally express interest in the Centers for Medicare & Medicaid Services Direct Contracting Model, for 2020 and 2021, until 11:59 p.m. Monday.

The deadline, which CMS postponed three days due to technical difficulties, marks a moment of truth for an initiative that some industry stakeholders have said could kickstart value-based primary care.

The agency is likely to receive a high number of non-binding letters of intent (LOI), many from organizations that will decide not to complete full applications, says Ashley Ridlon, policy leader at Evolent Health, which submitted an LOI "just in case."

Many details, including the benchmark methodology, risk adjustment approach, and capitated payment rate, have yet to be determined, as interested parties await a formal Request for Applications (RFA), Ridlon says.

"When you talk to some of the stakeholders who this model was supposedly designed for, you get some surprisingly tepid responses," she says. "One recently made a comment about not knowing if they are even eligible, given they don't currently have Medicare fee-for-service beneficiaries."

The first performance year, 2020, is intended for entities like that to enroll 5,000 or more Medicare beneficiaries, Ridlon says.

"The question may be more, do they really want to do all that enrollment work and make significant investments for a fee-for-service Medicare beneficiary population when they can get a patient panel handed to them much more easily and at lower expense through a private payer partnership?" she adds.

Organizations that don't submit an LOI by the deadline won't be allowed to complete applications, according to the CMS website.

Related: Medicare Just Invited More Competitors Into Value-Based Primary Care

Related: 5 Steps to Assess Your Readiness for CMS Primary Cares

Steven Porter is an associate content manager and Strategy editor for HealthLeaders, a Simplify Compliance brand.


The deadline is for non-binding letters of intent, so many who express interest may not follow through with full applications.

There are still many details that stakeholders are waiting to learn from the agency about how payments will be calculated.

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