The Honorable Xavier Becerra
Secretary
U.S. Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, DC 20201
Re: Continuing the Direct Contracting Model
Dear Secretary Becerra:
The undersigned organizations write to urge you to not cancel the Global and Professional Direct Contracting Model (GPDC) and instead make necessary refinements to improve the model in support of patients and providers. Direct Contracting is an accountable care model for traditional Medicare. Stopping Direct Contracting is bad policy and would undermine our health system’s move to value-based payment models, which is sorely needed to achieve the triple aim of better patient satisfaction, higher quality care, and more affordable care. Traditional Medicare patients’ care would be worse off without the benefits and quality of care provided by Direct Contracting Entities (DCEs).
Cancelling Direct Contracting would additionally undermine the work of the Center for Medicare and Medicaid Innovation (Innovation Center) and the Centers for Medicare & Medicaid Services (CMS). The Innovation Center was a critical part of the Affordable Care Act and is an instrument to test value-based payment models that make care more affordable while also improving quality of care. Much has been learned over its first decade of work. Should this model be abruptly ended, health care providers would be terminated from value-based payment participation without warning, making them far less likely to invest and participate in future CMS payment models. This would be particularly unfair for the dozens of Accountable Care Organizations (ACOs) that moved into Direct Contracting after the December 2021 conclusion of the Next Generation ACO Model, a successful provider-led payment model launched under then President Obama’s administration. The Innovation Center work and the shift to value-based care has been bipartisan and should remain that way.
Rather than cancelling Direct Contracting, a better option is to adjust the model, which the CMS Innovation Center can quickly do. Fix, don’t end, the Direct Contracting Model. For example, you can limit participation to certain types of DCEs, such as provider-led DCEs, and place additional guardrails and add more beneficiary protections. A rebranding and name change would also help communicate how this model is part of the evolution to accountable care. There’s still time to make these adjustments this year. The Innovation Center would also benefit from a public announcement that the Geographic Direct Contracting Model, which is being confused with the very different Global and Professional options, is stopped entirely.
Many of the recent criticisms against the model are misleading and flat out false. Traditional Medicare patients maintain their freedom of choice to see any willing provider. They keep all of their rights and protections, and in fact, get more benefits and lower cost care through the model. There are no networks or prior authorization. DCEs must inform patients of their assignment to a DCE. This is not the end of traditional Medicare, as advocates have falsely claimed, but is a way to provide additional beneficiary and provider tools as part of a whole-person care approach.
Furthermore, Direct Contracting is part of the CMS Innovation Center’s efforts to help underserved populations, a focus which should be built upon through program modifications. CMS officials have stated that DCEs have proportionately more providers in communities with high numbers of low-income and minority patients. The model in fact incentivizes care for sicker, high-needs patients. Lessons learned from the model could be applied to other payment models. Canceling Direct Contracting would hurt our health system’s efforts to address health disparities.
The organizations listed below have worked tirelessly, most recently in the face of a global pandemic, to move towards a health care delivery and payment system that emphasizes quality and value. During the pandemic, DCEs have been able to use care coordinators, telehealth, preventive care, and other waivers to keep patients healthy in the face of COVID. This work has been done despite challenges such as staff shortages, clinician burnout and grave financial struggles. Their work should be commended, not vilified.
Direct Contracting is a needed high-risk, value-based payment model designed to improve patient care. Please keep the model and make adjustments as needed or else we
Sincerely,
| AMDA-The Society for Post-Acute and Long-Term Care Medicine | Nevada Care Connect |
| America’s Physician Groups | NOMS Healthcare |
| AMGA | Northeast Georgia Health Partners |
| Association of American Medical Colleges | Northeast Georgia Physicians Group |
| Health Care Transformation Task Force | Northern Michigan Health Network dba NPO-CIN |
| Medical Group Management Association | Northern Ohio Medical Specialists, LLC |
| National Association of ACOs | Novello Physicians Organization |
| Premier healthcare alliance | Oak Street Health |
| Value Based Care Coalition | Ochsner Health |
| 360 Health | Ohio’s Hospice |
| Acclivity Health Solutions | Ohio’s Hospice of Dayton |
| Accountable Care Learning Collaborative | Ohio Integrated Care Providers |
| AdventHealth | Olympia Multispecialty Clinic |
| Advocate Aurora Health | On Belay Health Solutions |
| AEGIS Medical Group | Oncology Physicians Network |
| agilon health | Optima Medical |
| Akira MSO | OptimizeVBC |
| Akos MD IPA LLC | Optimus Healthcare Partners |
| Allied Pacific IPA | Optum – Southwest Medical Associates |
| Amarillo Legacy Medical ACO | Optum Care |
| American Multispecialty Group, Inc. dba Esse Health | Pathways Health Partners |
| Americas DCE | Pearl Health |
| Answer Health (Grand Rapids, MI) | Perfect Health (dba ConcertoCare) |
| Aon | Perfect Health DCE, LLC |
| APA ACO INC | Physicians Group of Southeastern Ohio (SE OH) |
| Apricus Health | Pinehurst Medical Clinic (Pinehurst, NC) |
| Apricus Health Network | Pioneer Physicians Network |
| Arcadia | Pioneer Physicians Network (Akron, OH) |
| Archway Health | The Portland Clinic |
| Arizona Care Network | PraxisCare Inc. |
| Arsenal Capital Partners | Preferred Primary Care Physicians (Pittsburgh, PA) |
| At Your Door Visiting Healthcare Services | Premier Family Physicians (Austin, TX) |
| Atlantic Accountable Care Organization | Primary Care Alliance |
| Atrium Health Wake Forest Baptist | Primary Medical Group |
| Austin Regional Clinic | PriMED |
| Babylon | PriMED Physicians |
| Babylon Health & Babylon Medical Group | Prime Holdings |
| Banner Health | Prisma Health Upstate Network |
| Bloom Healthcare | Pritesh & Tarak, PA |
| BrightHealth | Professional Health care of Pinellas LLC |
| Brown & Toland Physicians | Proficient Health |
| CareAllies | Prospect Medical Systems, Inc. |
| CareConnectMD | Providence |
| CareConnectMD DCE LLC | Providence Health and Services |
| CareDimensions LLC | Providence Medical Group, Inc. |
| Catholic Health Physician Partners ACO | Provider Partners Health Plan |
| Centene | PSW / NW Momentum Health Partners ACO |
| Central Ohio Primary Care | Pure Healthcare Inc. |
| ChenMed | Q Point Health, LLC (dba Equality Health Direct) |
| CHESS Health Solutions | Quality Independent Physicians |
| Chronic Disease Management LLC | Quincy Medical Group |
| Cityblock Health | Rancho Family Medical Group |
| ClaraPrice | RÃos Southwest MG |
| Collaborative Health Systems | Reemo Health |
| Complete Health | Reliance Hospice |
| Cone Health/Triad HealthCare Network | Renovis Health |
| David Stansfield DO LLC | Revere Health |
| DispatchHealth | Rios Southwest Medical Group |
| Dr Rios Medical Group | Robin Healthcare |
| Essentia Health | Saint Alphonsus Health Alliance |
| Executive Health of Coral Gables, LC | Sansum Clinic |
| Facey Medical Group | Scripps Coastal Medical Group |
| FamilyCare Medical Group (Syracuse, NY) | Sharp Community Medical Group |
| Fulshear Family Medicine | Sharp Community Medical Group Kenneth Roth |
| Genesis Health System | Sharp Rees-Stealy Medical Group |
| GeriNet Medical Associates Inc. | SIMEDHealth |
| Greater Newport Physicians | Southwestern Health Accountable Care Network |
| Greater San Antonio Emergency Physicians | Space Coast Independent Practice Association, LLC |
| Hail Health Cluster | St. Joseph’s University Medical Center |
| HealthPartners ACO | Starling Physicians (Hartford, CT) |
| Health Partners for the Elderly, LLC | Summit Health |
| Hernando Pasco Primary Care, LLC | Summit Medical Group, PLLC |
| Hospice of Central Ohio | Summit Reinsurance Services, Inc. |
| ilumed | Sutter Health |
| Innovaccer | Sutter Medicare Direct |
| Innovare Health Advocates | TCPA |
| Integrated Care Solutions | Texas Health Resources |
| INTEGRIS Health | Texas Panhandle Clinical Partners ACO |
| Intermountain Healthcare | TexasIPS |
| Iora Health/One Medical | Texoma ACO |
| IU Health | TMA |
| John Kuczynski MD | Trella Health |
| John Muir Medical Group | Triad HealthCare Network |
| KPN | TriHealth |
| Kronos Health, PLLC | Trinity Health |
| Lacey Medical Clinic | Trinity Health Integrated Care Accountable Care Organization |
| Lakeview Healthcare System | Tucson La Clinica Familiar |
| Linscott Family Practice | Tumwater Family Practice Clinic |
| Loyola Physician Partners | UHS/Prominence/ACO Management Services |
| Lumeris | UMass Memorial Health |
| Magnolia Clinica Medica Familiar | United Church Homes, Inc |
| MaineHealth Accountable Care Organization | UnityPoint Accountable Care |
| Mary Washington Health Alliance LLC | University of Texas Southwestern Medical Center |
| MaxHealth | UpStream Healthcare |
| McAuley Health Partners ACO, LLC | Validate Health |
| MD Valuecare LLC | ValueH |
| Medcare Wellvana Pediatric Cardiology | Vancouver Clinic |
| Medical Home Network | Vicinia Health |
| MemorialCare Medical Group | Vikas Desai MD PC |
| MercyOne PHSO | Village Medical at Home |
| Methodist Patient Centered ACO | VillageMD |
| The MetroHealth System | VillageMD Primary Providers ACO |
| MHN ACO | VillageMD Arizona ACO |
| MMC Advisors LLC | VillageMD Georgia ACO |
| Motog Inc. D/B/A St. Francois Medical Center | VillageMD Houston ACO |
| Mount Sinai Health System | VillageMD Michigan ACO |
| MSO of Puerto Rico, LLC | VillageMD New Hampshire ACO |
| MultiCare Health System | Wellvana Health |
| Muskingum Valley Health Center | Wilems Resource Group |
| MyCare Pinellas, PA | Wilmington Health |
| Nath Holdings LLC | Zia ACO |