Mid-Atlantic Health Law TOPICS

As the Maryland Primary Care Program (MDPCP) pilot continues, the Maryland Department of Health announced planned expansions for the program that will go into effect in 2023.

The MDPCP is a voluntary program open to primary care providers and Federally Qualified Health Centers (FQHCs) designed to reduce overall spending for traditional Medicare beneficiaries in Maryland by incentivizing practices to use advanced primary care services and coordination for patients, with the intent of increasing quality and reducing hospitalizations and other costs.

In 2022, the MDPCP is slated to reach over four million Maryland patients via 545 sites and over 2,000 providers.

Tracks 1 and 2

When the MDPCP began in 2019, participating practices chose between one of either Track 1 (Standard Track) or Track 2 (Advanced Track). Both tracks require practices to provide comprehensive primary care functions to patients, but at different levels. As a result, the practices offering more complex care management services received generally higher payouts from the MDPCP.   

The underlying payment model also changes between the two tracks. In Track 1, PCPs continue to operate under the traditional Medicare Fee for Service (FFS) model. However, Track 2 uses a hybrid model that shifts payments away from FFS and into Comprehensive Primary Care Payments (CPCPs), paid in advance on a quarterly basis. The amount of the practices’ payments made via CPCPs increases over time.

Track 3

In January of 2023, CMS will open Track 3, allowing providers time to transition to Track 2 or 3 before CMS closes Track 1 at the end of 2023.

Track 3 increases the total cost of care accountability of participating primary care practices by introducing upside and downside risk based on practice performance on cost and quality metrics.

Unlike the earlier tracks, Track 3 does not include a Care Management Fee (CMF), a Performance Based Incentive Payment (PBIP), or a CPCP. Instead, Track Three participants will receive a Total Primary Care Payment (TPCP).

The TPCP consists of two parts: (1) a Population-Based Payment (PBP) that pays a portion of fee-for-service prospectively; and (2) a Flat Visit Fee (FVF) at the time of service for certain primary care services.

Track 3 also introduces risk through a positive or negative Performance Based Adjustment (PBA) based on measures of quality, utilization and total cost of care.  

Track 3 participants can also receive a Health Equity Advancement and Resource Transformation (HEART) payment for practices to identify health-related social needs for high-cost and socioeconomically disadvantaged Medicare beneficiaries, and to address complex needs while improving health outcomes.

Alexandria K. Montanio
410-576-4278 • amontanio@gfrlaw.com