Direct Provider Contracting: Keep It Simple, Stakeholders Tell CMS

For the most part, providers support the Direct Provider Contracting proposal put forward by the Centers for Medicare & Medicaid Services, with some stipulations and considerable tweaking.

Key stakeholders are mostly supportive of a Medicare Direct Provider Contracting proposal but urging the federal government to keep it simple and not overwhelm providers with paperwork.

"Burden reduction must be a priority for the Innovation Center when implementing the DPC model," the Medical Group Management Association said in a letter to the Centers for Medicare & Medicaid Services.

"Collecting and reporting quality metrics remain technically challenging, data intensive, and administratively burdensome," MGMA said. "Bureaucratic barriers to care, including prior authorization and appropriate use criteria, are at odds with care delivery and financial models in which participants are accountable for care outcomes."  

That concern was echoed by The American Geriatrics Society, which urged that "CMS take care not to add further administrative burdens that may negatively impact patient care."

The National Association of Accountable Care Organization supports the DPC concept, but urged CMS to limit participation to primary care providers for the rollout.

"Primary care is more appropriate for this type of model, and specialty DPC Models would be too similar to bundled payment programs," NAACOS said. "Further, it would be much more complicated to structure per beneficiary per month payments for specialty care which is typically more complex and can include episodes of care with greater variation in clinical conditions, treatment protocols and related costs."

NAACOS argued that starting with a primary care focus would allow CMS to test the concept while focusing on beneficiary protections without having to consider more complex specialty-focused DPC models.

"For purposes of beginning a DPC Model test, CMS would contract directly with primary care practices to establish the practice as the main source of primary care for services," NAACOS said.

'Yet Another Capitation Scheme'

The Association of American Physicians & Surgeons said it was "disappointed" with the proposal, which it said "turns the concept on its head."

"The title of the RFI itself signals an unfortunate transformation of DPC from Direct Patient Care into what CMS calls, 'Direct Provider Contracting,'" AAPS said in its letter to CMS.

"We are concerned that CMS is not encouraging direct arrangements between patients and physicians. The RFI explains that to CMS, DPC means "direct provider contracting (DPC), through which CMS would directly contract with Medicare providers,'" AAPS said.

"In addition, CMS asks for feedback on countless requirements and conditions it is considering imposing on physicians seeking to contract with CMS," AAPS said.

"To us and our members, this approach by CMS looks much more like yet another third-party-controlled ACO or capitation scheme than anything resembling the agreements Direct Primary Care practices are currently offering their patients," AAPS said.