The Centers for Medicare and Medicaid Services (CMS) recently announced a redesign of the Global and Professional Direct Contracting Model (the GPDC Model) and renamed the GPDC Model the ACO REACH Model. (“REACH” stands for Realizing Equity, Access, and Community Health.) Applications for the new ACO REACH Model are accepted beginning March 7, 2022 and close on April 22, 2022, for participation to begin on January 1, 2023 and run for four (4) performance years. Accepted applications have an option of participating in a 4-month implementation period (August 1, 2022 through December 31, 2022) in advance of the first performance year.
The redesign comes after rumors of the potential cancellation of the politically polarizing GDPC Model. CMS simultaneously announced the permanent cancellation of the Geographic Direct Contracting (GDC) Model, which had been paused since March of 2021.
Under the GPDC Model, participating providers are able to obtain certain enhanced programmatic benefits under Medicare while taking on higher risk through partial or full capitation. Participating providers receive reduced Medicare payments and agree to receive some compensation from the DCE that has the participation contract with CMS. There were two participant options:
Both the Professional and Global Options meet the criteria to be Advanced Alternative Payment Models (APMs) in performance years 2021 and 2022, and are both considered Merit-based Incentive Payment Systems (MIPS) APMs.
In announcing the redesign, CMS indicated that the revisions reflect the priorities of the Biden Administration and address legislative criticisms of components of the GPDC Model. Such priorities include: (i) a focus on health equity and bringing the benefits of value-based care to underserved communities; (ii) the promotion of provider leadership, ownership, and governance to help ensure more provider controlled governance; and (iii) additional vetting and monitoring of information, including on ownership, leadership, operations, and governance to help protect beneficiaries. The GPDC Model faced growing criticism from certain members of Congress. The criticisms alleged, among other things, that the GPDC Model was leading to the privatization of Medicare, which threatened access to quality health care, as investor-owned entities were reportedly taking ownership and control positions in Direct Contracting Enterprises (DCEs), and that DCEs had used up-coding to game beneficiary risk scores.
ACO REACH Model makes material changes to the GPDC Model. Notable changes include:
There also will be model changes reducing the withholds for quality, which encourages provider participation compared to other Innovation Center models (e.g., Direct Contracting); reducing the discount rate before 100% risk sharing occurs in the Global option, which encourages provider participation in the Global option; and modifying the risk categories to mitigate inappropriate risk score gaming. The benchmark for ACO’s serving a higher proportion of underserved beneficiaries will also be increased to help ensure all Medicare beneficiaries are served.
The summary above describes notable changes in the Model redesign. A CMS summary chart of the policy revisions in the model redesign is available here.
Current GPDC Model participants must maintain a strong compliance record in 2022 and agree to meet all of the ACO REACH Model requirements beginning January 1, 2023 in order to continue as participants in the ACO REACH Model. Based on current Innovation Center guidance and instructions, GPDC Model participants will sign new participation agreements, but are not required to re-apply, to participate in the ACO Reach Model.
****As CMS and its Innovation Center continue to test and define value-based programs, they are addressing criticisms made concerning the GPDC Model and are focused on reducing health care inequities in underserved communities in the redesign and renaming of the GPDC Model. The redesign provides an opportunity for those that expected to apply for participation in 2021 before the GDPC Model was abruptly closed to new applicants, and leaves existing GDPC Model participants to decide whether REACH is the correct path for them and their providers.