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Making Care Primary: Top insights into the new CMS initiative

CMS recently announced its newest Center for Medicare and Medicaid Innovation (CMMI) model: Making Care Primary (MCP). 

Goal of MCP1

    1. Ensure patients receive primary care that is integrated, coordinated, person-centered and accountable.
    2. Create a pathway for primary care organizations and practices – especially small, independent, rural, and safety net organizations – to enter into value-based care arrangements.
    3. Improve the quality of care and health outcomes for patients while reducing program expenditures.

Important to note: Practices currently participating in the Primary Care First model are not allowed to participate in MCP.

Implementation Details and Requirements2

    • There will be a multi-state integration beginning in eight states: Colorado, New Mexico, Massachusetts, Minnesota, New Jersey, New York, North Carolina, and Washington.
        • CMS selected these states because they met criteria related to:
            • Geographic diversity.
            • Health equity opportunities.
            • Current CMMI footprint.
            • Generalizability to the Medicare population.
            • Alignment with State Medicaid agencies.
    • Practices must be Medicare enrolled and bill for health services for at least 125 Medicare enrollees on panel.
    • Practices must have more than 51% of their primary care sites located in a MCP state.

MCP Model Design

MCP is CMS’s longest model released to date – a 10.5-year performance period – and includes three progressive tracks of participation, with a phase-in to fully prospective, population-based payments in Track 3.

The three track options include:2

    • Track 1 –Building Infrastructure: Participants begin developing the foundation for advanced primary care service implementation. This includes:
        • Risk-stratifying their population;
        • Reviewing data;
        • Building out workflows;
        • Identifying staff for chronic disease management; and
        • Conducting health-related social needs screening and referral.

Payment for primary care will remain fee-for-service (FFS), while CMS provides additional financial support. Participants can begin earning financial rewards for improving patient health outcomes in this track.

    • Track 2 – Implementing Advanced Primary Care: Participants build upon Track 1 by partnering with social service providers and specialists, implementing care management services, and systematically screening for behavioral health conditions.

Payment for primary care will shift to a 50/50 blend of prospective, population-based payments and FFS payments. CMS will continue to provide additional financial support, but at a lower level than Track 1. Participants will be able to earn increased financial rewards for improving patient health outcomes. 

    • Track 3 – Optimizing Care and Partnerships: Here, participants will expand upon the requirements of Tracks 1 and 2 by using quality improvement frameworks to:
        • Optimize and improve workflows;
        • Address care silos;
        • Develop social services and specialty care partnerships; and
        • Deepen connections to community resources.

Payment for primary care will shift to fully prospective, population-based payment while CMS will continue to provide additional financial support, at a lower level than Track 2. Participants continue to have the opportunity to earn financial rewards for improving patient health outcomes.

CMS released a formal Request for Applications in August 2023 where interested organizations could submit a non-binding Letter of Intent to CMS. 

Contact us to see how a partnership with Lifepoint can provide the necessary regulatory support to help your hospital make the best decision for your patients, staff and community.


    1. Centers for Medicare and Medicaid Services. (2023, June). Press release CMS announces multi-state initiative to Strengthen Primary Care. CMS.
    2. ATI Advisory. (2023, July). Making Care Primary (MCP) FQHC and IHP Overview Webinar. PPT

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