CMS’ Making Care Primary (MCP) Model: Applications Due November 30, 2023
The Centers for Medicare and Medicaid Services’ (CMS) new program Making Care Primary (MCP), is anticipated to begin July 1, 2024.
In a previous blog post Foley breaks down major highlights of the new model.
On September 5, 2023, applications opened. Eligible providers have until November 30, 2023 to submit their applications to CMS. As identified in the Scope section, CMS is accepting applications from Medicare-enrolled organizations located in the following states: Colorado, Massachusetts, Minnesota, New Mexico, New Jersey, upstate New York, North Carolina, and Washington.
The following types of organizations are eligible to apply to participate in MCP: Medicare-enrolled organizations that provide primary care services to Medicare beneficiaries, including solo primary care practices, group practices, health systems, Federally Qualified Health Centers (FQHCs), and eligible Indian Health (Tribal) Programs. Critical Access Hospitals (CAHs) that have selected “Standard” or “Method I” billing may also apply.
To be eligible to apply to participate in MCP, an organization must: (1) be a legal entity formed under applicable state, federal, or Tribal law, that is authorized to conduct business in each state in which it operates; (2) be Medicare-enrolled; (3) serve as the regular source of primary care for a minimum of 125 attributed Medicare beneficiaries; and (4) have the majority (at least 51%) of their primary care site(s) (physical locations where care is delivered) located in an MCP state described in the Scope section of the application.
In addition, applicants that are not FQHCs must bill Medicare for services furnished by primary care clinicians (Doctors of Medicine, Doctors of Osteopathic Medicine, Clinical Nurse Specialists, Nurse Practitioners, Physician Assistants) who provide primary care services as part of their job. CMS defines primary care clinicians for the purposes of the application as a list of National Plan & Provider Enumeration System (NPPES) specialties that represent “primary care,” including internal medicine, general medicine, geriatric medicine, family medicine, pediatrics, nurse practitioner, clinical nurse specialist, and physician assistant. Non-FQHC applicants must also have primary care services account for at least 40% of the applicant’s collective Medicare revenue for the list of primary care clinicians employed by the applicant. Non-FQHC applicants must identify, in the application, each individual primary care that renders services under the Taxpayer Identification Number (TIN) of the applicant – otherwise known as the MCP Clinician List – by their National Provider Identifier (NPI).
Applicants that are interested in MCP but aren’t ready to apply can also complete the short, online letter of interest (LOI), to signal their interest to the Center for Medicare & Medicaid Innovation (CMS Innovation Center) and sign up to learn more about the model as information is released.
The deadline for eligible providers to submit their applications to CMS has been extended to December 14, 2023.
Foley is here to help you address the short- and long-term impacts in the wake of regulatory changes. We have the resources to help you navigate these and other important legal considerations related to business operations and industry-specific issues. Please reach out to the authors, your Foley relationship partner, or to our Health Care Practice Group with any questions.
