DPC Alliance comments on CMS RFI on DPC

Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

Dear Administrator Verma,

The Direct Primary Care Alliance is a membership organization of Direct Primary Care (DPC) physicians who own and operate small, independent DPC practices. The Alliance was born from a grassroots network of practicing DPC physicians looking to provide resources and a unified voice for fellow DPC physicians. From 50 founding members-- pioneers and leaders of the DPC movement-- we have quickly grown to over 200 physician-members from across the nation; mostly family physicians who own and operate small, community-based DPC practices.

Thank you for the opportunity to submit comments in response to the CMS Center for Medicare and Medicaid Innovation Request for Information (RFI) on “Direct Provider Contracting” models. The information we are sharing here is intended to help CMS better understand the perspective of our members.

The RFI has a stated goal to “empower beneficiaries as consumers, increase choices and competition to drive quality, reduce costs and improve outcomes.” We absolutely agree with this objective and believe the DPC model is already doing exactly that. We are doing so without any external incentives or directives. By freeing ourselves from many of the burdens associated with the traditional complexities of third-party billing, we are able to better focus our time and efforts on improving the care and experience of our patients, including Medicare beneficiaries. There is not a better example of putting “Patients Over Paperwork” as you have suggested as a priority for CMS initiatives.

For a number of years, the DPC community has been communicating with CMS about how DPC practices are serving patients in this innovative model. The DPC Alliance Board of Directors value CMMI's inquiry through this RFI. We believe physicians in active DPC practices are most suited to provide input into programs that involve payment initiatives and direct primary care. Below we have outlined our specific concerns and suggestion about the RFI as it stands. In the remainder of the document, we address each question specifically.

The Direct Primary Care Alliance respectfully requests the following:

  1. Please rename the program. “Direct Provider Contracting” is new terminology but mirrors the D.P.C. acronym associated with “Direct Primary Care”. While we understand taking a broad view on alternative payment models, the phrase “Direct Primary Care“ and the acronym DPC has a long history of use dating back to late 2000’s. There are over 800 Direct Primary Care practices nationwide using the DPC phrase and acronym. Also, Direct Primary Care was codified in the Affordable Care Act (section 1301a), and to date, 25 states have legislation defining the “Direct Primary Care” model. It is for this reason that the use of “DPC” in the remainder of this introductory letter will specifically mean direct primary care, not direct provider contracting.

    So, it would seem appropriate to avoid creating a new phrase with a DPC acronym as it may create confusion among physicians, policymakers, state legislators and patients (including Medicare beneficiaries).

  2. We encourage CMS to create a program with a truly innovative approach built around direct payment from beneficiaries to the DPC practice via a subsidized personal account. The best option to do this within existing Medicare programs would seem to be “Medical Savings Accounts” (MSA). However, to fully maximize the use of MSAs within DPC practices, several alterations would be required. First, MSAs should be untied from private Medicare Advantage plans. Allowing the beneficiaries to choose a subsidized MSA within traditional Part B coverage would be the simplest approach. Alternatively, a new type of personal account could be created by CMS that was geared towards primary care services or specifically the DPC model. Either way, this account could be used to pay a DPC provider simply via a standard electronic transfer (debit or EBT). With any type of account, we suggest maximum beneficiary ownership and flexibility of those dollars; including clarification that DPC fees are an eligible expense.

    The RFI references the existing Alternative Payment Models (APMs) of CPC+ and ACOs. While a broader frame of reference is reasonable, these models are fundamentally different than the DPC model as it’s widely practiced. The majority of DPC practices are built upon a simple, direct relationship with a patient with limited to no involvement from third-party payors. We do not believe building upon the framework of the CPC+ and ACOs programs to be in-line with the principles of the DPC model.

    The majority of our physician members would not be inclined to participate in a capitation payment program, nor an ACO.

  3. For maximum physician participation, the opt-out status of existing DPC providers will need to be addressed. The vast majority of members of the Direct Primary Care Alliance have opted-out of Medicare so that they may freely enter into private DPC agreements with Medicare beneficiaries. While this is a necessity under current Medicare rules, it’s less than ideal for both physicians and beneficiaries.

    The opt-out decision creates a dilemma for physicians who are sometimes required to remain a Medicare participating provider for employed positions as their DPC practice is growing. During this stage, these physicians cannot legally enter into private agreements with Medicare beneficiaries for DPC services.

    CMMI will need to address this matter without mandating these physicians be full participants in traditional Medicare. We suggest allowing any physician and Medicare beneficiary to enter into a “private contract” arrangement for DPC services on a case-by-case basis irrespective of the provider’s participation in the Medicare program.


Thank you for considering a program that empowers high-quality physician-patient relationships and reduced cost of care. We hope that CMMI will create a transformational program that supports the patient-centered ideals foundational to Direct Primary Care while retaining its revolutionary simplicity. This type of innovative solution is necessary for Medicare beneficiaries, primary care physicians, and the nation. The Direct Primary Care Alliance is eager to engage with CMMI on this project and are happy to assist in any way possible.

Respectfully submitted,

Direct Primary Care Alliance

Ryan Neuhofel, DO MPH  |  President
Julie Gunther, MD  | Vice President
Amy Walsh, MD  | Treasurer
Allison Edwards, MD  | Secretary

Michael Ciampi, MD | Lisa Davidson, DO  | Douglas Farrago, MD | Jeffrey Gold, MD  | Jennifer Harader, MD | Vance Lassey, MD |  Kimberly Legg-Corba, DO | Josh Umbehr, MD | Kylie Vannaman, MD

Answers to the specific questions within RFI


Questions Related to Provider/State Participation

1.  How can a DPC model be designed to attract a wide variety of practices, including small,
independent practices, and/or physicians? Specifically, is it feasible or desirable for
practices to be able to participate independently or, instead, through a convening
organization such as an ACO, physician network, orother arrangement?

Given that small, independent practices encompass 70-90% of the DPC market, this is a crucial consideration. The majority of DPC practices operate with very low-overhead and employ very few staff members; often having no clerical or billing staff. Most DPC practices bill their patients through a monthly recurring, automatic transfer of funds via credit/debit card or checking account-- similar to subscribing to Netflix or paying for a gym membership. Several electronic billing/payment systems are used to streamline this process. As such, very little time is spent on matters of billing or payment within DPC practices.

To make any CMS program viable for these practices, there must be a very simple payment mechanism that mimics current DPC operations. We recommend giving Medicare beneficiaries an option for “personal account” (as described in other places in this document) to use for payment of DPC services. The EBT system at grocery stores works well for people receiving food assistance. We see no reason why it couldn’t also work for Medicare beneficiaries paying for DPC services.

Any type of third-party payment (from CMS, network manager, or ACO) to DPC practice would not be an ideal, or perhaps even acceptable, to majority of our members. Inevitably, these arrangements add administrative complexity, overhead cost and detracts from patient care.

2. What features should CMS require practices to demonstrate in order for practices to be
able to participate in a DPC model (e.g., use of certified EHR technology, certain
organizational structure requirements, certain safeguards to ensure beneficiaries receive
high quality and necessary care, minimum percent of revenue in similar arrangements,
experience with patient enrollment, staffing and staff competencies, level of risk
assumption, repayment/reserve requirements)? Should these features or requirements
vary for those practices that are already part of similar arrangements with other payers
versus those that are new to such arrangements? If so, please provide specific examples
of features or requirements CMS should include in a DPC model and, if applicable, for
which practice types.

Physicians are heavily regulated through state licensure, medical boards and, often, their local physician community and medical staff credentialing office. To date, approximately 25 states have set legal definitions of DPC-- namely to clarify it as “not insurance”-- and most of them provide consumer protections for participating patients. We are supportive of these existing laws and protections, but would not suggest extra layers of accreditation or verification of physicians practicing in the DPC model.  

3. What support would physicians and/or practices need from CMS to participate in a DPC
model (e.g., technical assistance around health IT implementation, administrative
workflow support)? What types of data (e.g., claims data for items and services furnished
by non-DPC practice providers and suppliers, financial feedback reports for DPC
practices) would physicians and/or practices need and with what frequency, and to
support which specific activities? What types of support would practices need to
effectively understand and utilize this data? How should CMS consider and/or address
the initial upfront investment that physicians and practices bear when joining a new

The DPC movement has grown organically in the past 7 years from about a dozen to over 800 PCPs without investment from CMS or any large entities. These physicians have taken the financial risk of starting and building a practice independently which is a testament to the entrepreneurial nature of Direct Primary Care.

The burden of sorting through current medical history and documentation is tremendous. This is particularly true for primary care providers  attempting to play quarterback for patients with multiple providers. To improve this process, we are in favor of physicians having better access to clinical data (diagnosis list, results, etc.). The best way to accomplish this would be continued efforts to support interoperability of electronic health records, but also returning patients to a custodial role of their own health records when feasible.

While billing and claims data (centered around CPT coding) may be useful in a systemic analysis, this data is not helpful with clinical decision making nor does it facilitate collaborative care among providers. We do not recommend this be a significant aspect of this program at the provider level.

4. Which Medicaid State Plan and other Medicaid authorities do States require to implement
DPC arrangements in their Medicaid programs? What supports or technical assistance
would States need from CMS to establish DPC arrangements in Medicaid?

The structure and regulation of Medicaid is unique to each state, but we would suggest following the principles we outline here for each of those states considering DPC.

5. CMS is also interested in understanding the experience of physicians and practices that
are currently entirely dedicated to direct primary care and/or DPC-type arrangements. For
purposes of this question, direct primary care arrangements may include those
arrangements where physicians or practices contract directly with patients for primary
care services, arrangements where practices contract with a payer for a fixed primary care
payment, or other arrangements. Please share information about: how your practice
defines direct primary care; whether your practice ever participated in Medicare; whether
your practice ever participated in any fee-for-service payment arrangements withthird party
payers; how you made the transition to solely direct contracting arrangements (if
applicable); and key lessons learned in moving away from fee-for-service entirely (if

The majority of our members have launched DPC practices as personal entrepreneurial ventures. Most of them have done so after practicing in traditional, fee-for-service settings both as practice owners and employees. It is widely recognized that the administrative burdens and time-crunched nature of traditional models of primary care are contributing to physician “burnout”; our members echo this sentiment.

Most of our members are familiar with caring for Medicare beneficiaries under available payment models; including many of the “innovative” programs discussed in this RFI. These limitations are largely what have driven them to pursue the DPC model.

Questions Related to Beneficiary Participation

6. Medicare FFS beneficiaries have freedom of choice of any Medicare provider or supplier,
including under all current Innovation Center models. Given this, should there be limits
under a DPC model on when a beneficiary can enroll or disenroll with a practice for the
purposes of the model (while still retaining freedom of choice of provider or supplier
even while enrolled in the DPC practice), or how frequently beneficiaries can change
practices for the purposes of adjusting PBPM payments under the DPC model? If the
practice is accountable for all or a portion of the total cost of care for a beneficiary,
should there be a minimum enrollment period for a beneficiary? Under what
circumstances, if any, should a provider or supplier be able to refuse to enroll or choose
to disenroll a beneficiary?

We support giving Medicare beneficiaries freedom of choice of where and how they receive primary care, including the ability to choose a DPC practice or a traditional FFS practice. The simplest way to ensure this freedom of choice is to provide Medicare beneficiaries a subsidized personal account that can be used to pay for primary care services. There is variation among DPC practices--including variation in monthly rate, enrollment charges, etc..--but most DPC clinics charge monthly memberships with no minimum enrollment requirement. In this arrangement, the DPC practice must constantly prove their service and value to patients. Quality is assured by the inherent understanding that a patient who feels they are not receiving proper care may leave the practice at any time and find a different provider.

This is why DPC works. DPC models support the absolute right of a patient and physician to enter in to a primary care relationship. If the relationship is not a good fit or a patient is dissatisfied with access, the care provided and even with the charges, the patient is empowered to find a clinic that suits their needs.

7. What support do practices need to conduct outreach to their patients and enroll them
under a DPC model? How much time would practices need to “ramp up” and how can
CMS best facilitate the process? How should beneficiaries be incentivized to enroll? Is
active enrollment sufficient to ensure beneficiary engagement? Should beneficiaries who
have chosen to enroll in a practice under a DPC model be required to enter into an
agreement with their DPC-participating health care provider, and, if so, would this
provide a useful or sufficient mechanism for active beneficiary engagement, or should
DPC providers be permitted to use additional beneficiary engagement incentives (e.g.,
nominal cash incentives, gift cards)? What other tools would be helpful for beneficiaries
to become more engaged and active consumers of health care services together with their
family members and caregivers (e.g., tools to access to their health information,
mechanisms to provide feedback on patient experience)?

We believe it is the responsibility of the DPC practice to actively recruit patients within their communities. This education and outreach is part of building a strong community-based clinic and DPC practices are comfortable in that role. If CMMI were to launch a program, we would expect existing DPC practices to grow to meet that demand. We also expect new DPC practices to open. If CMMI were to be involved in marketing this program, we would suggest a simple notification to Medicare beneficiaries that DPC fees are an eligible expense using this new benefit.

8. The Medicare program, specifically Medicare Part B, has certain beneficiary cost-sharing
requirements, including Part B premiums, a Part B deductible, and 20 percent
coinsurancefor most Part B services once the deductible is met. CMS understands that

existing DPC arrangements outside the Medicare FFS program may include parameters
such as no coinsurance or deductible for getting services from the DPC-participating
practice or a fixed fee paid to the practice for primary care services. Given the existing
structure of Medicare FFS, are these types of incentives necessary to test a DPC
initiative? If so, how would they interact with Medicare supplemental (Medigap) or other
supplemental coverage? Are there any other payment considerations or arrangements

CMS should take into account?

We suggest that DPC practices not be entangled in any of the payment systems currently existing for Medicare beneficiaries. Any care that a patient receives outside of a DPC practice including subspecialty referrals and hospitalization will be paid under the customary plans available.

Questions Related to Payment

9. To ensure a consistent and predictable cash flow mechanism to practices, CMS is
considering paying a PBPM payment to practices participating in a potential DPC model
test. Which currently covered Medicare services, supplies, tests or procedures should be
included in the monthly PBPM payment? (CMS would appreciate specific Current
Procedural Terminology (CPT®1)/Healthcare Common Procedure Coding System (HCPCS) codes as examples, as well as ICD-10-CM diagnosis codes and/or ICD-10-PCS
procedure codes, if applicable.) Should items and services furnished by providers and
suppliers other than the DPC-participating practice be included? Should monthly
payments to DPC-participating practices be risk adjusted and/or geographically adjusted,
and, if so, how? What adjustments, such as risk adjustment approaches for patient
characteristics, should be considered for calculating the PBPM payment?

As a comprehensive primary care model, the vast majority of DPC practices offer a wide spectrum of care, including preventive care, acute care for illness and injuries and chronic disease management. The vast majority do all this in exchange for a fixed, recurring monthly membership fee without additional charges (e.g. co-pays) for any visits or communication.

In addition, DPC practices have negotiated for and provide their members with access to heavily discounted services, including procedures, lab work, radiology (imaging) and generic medications.  These services are heavily discounted because the burden of third-party reporting, billing, and filing is removed. One of the reasons we favor a subsidized “personal account” benefit (payment to beneficiary) is to allow those dollars to be used flexibly within the DPC practices to pay for these ancillary charges. This would be the best way to utilize the full value of the full DPC model for CMS and the beneficiary.

Regarding a list of specific covered CPT codes within the primary care sphere, we simply suggest that any list would be inherently overreaching and not intended to guide the services of the DPC practice. One of the benefits of the DPC model is that primary care providers do not need to think about what is a billable encounter or not. We can flexibly meet the needs of our patients independent of whether the care provided is ‘codable’ or not..  

We have not found DPC pricing to vary considerably enough regionally to advocate for geographic adjustments in this program. This project could be ‘over-thought’ with small details adding unnecessary complexity  and unnecessary administrative burden at increased expense without improving the care of Medicare beneficiaries. We advocate for the simplest program possible.

As primary care physicians, we realize that health and wellness often comes with peaks and valleys. For this reason, we believe access to quality primary care should be a paramount goal for all patients regardless of their current health status. While a certain subset of patients will be chronically very ill, there is significant turnover in the high-utilizer group from year to year.

Risk-adjusted benefits- e.g. giving a higher monthly subsidy to an individual deemed to be in poorer health-- would be extremely complicated for a number of reasons and is something we currently recommend against.

10. How could CMS structure the PBPM payment such that practices of varying sizes would
be able to participate? What, if any, financial safeguards or protections should be offered
to practices in cases where DPC-enrolled beneficiaries use a greater than anticipated
intensity or volume of services either furnished by the practice itself or furnished by other
health care providers?

If this program is structured around individual beneficiaries, there would no need to vary the program based on size of DPC practice or market. There may be some DPC practices with a large number of providers, where others will be solo practice or small group. Regardless, the beneficiary should be able to free choose a DPC practice that provides the best value and service for them.

Utilization considerations are fundamental to any membership-based business. While DPC practices must be mindful of utilization and pricing for business success, we do not suggest added safeguards for practices related to utilization. We do not believe this program-- more Medicare beneficiaries utilizing DPC clinics-- will impact this dynamic.  

 11. Should practices be at risk financially (“upside and downside risk”) for all or a portion of
the total cost of care for Medicare beneficiaries enrolled in their practice, including for
services beyond those covered under the monthly PBPM payment? If so, what services
should be included and how should the level of risk be determined? What are the
potential mechanisms for and amount of savings in total cost of care that practices
anticipate in a DPC model? In addition, should a DPC model offergraduated levels of
risk for smaller or newer practices?

DPC practices should not be penalized or rewarded for the total or downstream (non-primary care) costs of care. Asking primary care physicians to ‘share risk,’ via ACO or other means, has not been shown to improve the quality of care or patient-outcomes. Rather, we believe an opportunity to provide great primary care is tremendously important; the DPC model affords PCPs exactly that.

Multiple efforts have been undertaken to define direct primary care as not related to nor similar to insurance-like, risk-adjusted models. 25 states have laws stating exactly this. Direct primary care practices offer as-needed access to the primary care doctor without consideration of risk pools or the burden of billing and coding. The physicians job is to care for their patient.  Adding other responsibilities, covered services, and risk adjustments mutates this clear objective and relationship.

12. What additional payment structures could be used that would benefit both physicians and

As suggested above, harnessing the transformative nature of DPC, a Medical Savings Account (MSA) plus a modified version of Part B coverage could be revolutionary model for Medicare beneficiaries.

Questions Related to General Model Design

13. As part of the Agency’s guiding principles in considering new models, CMS is
committed to reducing burdensome requirements. However, there are certain aspects of
any model for which CMS may need practice and/or beneficiary data, including for
purposes of calculating coinsurance/deductible amounts, obtaining encounter data and
other information for risk adjustment, assessing quality performance, monitoring
practices for compliance and program integrity, and conducting an independent
evaluation. How can CMS best gather this necessary data while limiting burden to model
participants? Are there specific data collection mechanisms, or existing tools that could
be leveraged that would make this less burdensome to physicians, practices, and
beneficiaries? How can CMS foster alignment between requirements for a DPC model
and commercial payer arrangements to reduce burden for practices?

We recommend monitoring Medicare beneficiaries through spending via their personal account. These debit transactions will contain basic financial information to assure program compliance and monitor for fraud. This type of monitoring has proven quite effective within food assistance programs via EBT (SNAP) cards at grocers. The rates of fraud within those EBT driven programs are much less than exists within current Medicare third-party payments.

14. Should quality performance of DPC-participating practices be determined and
benchmarked in a different way under a potential DPC model than it has been in ACO
initiatives, the CPC+ Model, or other current CMS initiatives? How should performance
on quality be factored into payment and/or determinations of performance-based
incentives fortotal cost of care? What specific quality measures should be used or

The ability to objectively measure “performance” or “quality” of primary care has proven extremely challenging. To date, the vast majority of attempts at doing such have proven invalid. This is widely supported in the literature (N Engl J Med 2018; 378:1757-1761, https://www.nejm.org/doi/full/10.1056/NEJMp1802595?query=TOC).

We are happy that the discussion about quality has moved away from burdensome measures of process and now focusing on health outcomes. However, this also poses dilemmas and potential moral hazards. Given 70% or more of health outcomes are based on lifestyle and socioeconomic factors, medical care providers are limited in many respects. With great primary care, it is possible to move a patient or group of patients towards better health and less downstream spending. However, comparing the outcome of one patient or group of patients to another is often not helpful. Even with risk-adjustments-- a complicated and imprecise process-- defining good outcomes or benchmarks is often murky.

To measure the financial success of this program (a wider adoption of DPC), we would suggest monitoring the downstream costs of participating beneficiaries. While some benefits may be realized quickly, we would suggest a minimum of 3 years to allow for variances in utilization, increased costs of care at start-up and challenges intrinsic to anything new.  Cost-savings data amortized over 3 years across a number of existing DPC practices can be anticipated to be 20% of total healthcare spend per beneficiary.

15. What other DPC models should CMS consider? Are there other direct contracting
arrangements in the commercial sector and/or with Medicare Advantage plans that CMS
should consider testing in FFS Medicare and/or Medicaid? Are there particular
considerations for Medicaid, or for dually eligible beneficiaries, that CMS should factor

in to designing incentives for beneficiaries and health care providers, eligibility
requirements, and/or payment structure? Are there ways in which CMS could restructure
and/or modify any current initiatives to meet the objectives of a DPC model?

As currently structured, we do not believe the majority of our membership would find any utility in participating in existing Medicare Advantage plans. However we are open to solutions that are elective, simple, transparent and cost-effective.

Questions Related to Program Integrity and Beneficiary Protections

16. CMS wants to ensure that beneficiaries receive necessary care of high quality in a DPC
model and that stinting on needed care does not occur. What safeguards can be put in
place to help ensure this? What monitoring methods can CMS employ to determine if
beneficiaries are receiving the care that they need at the right time? What data or
methods would be needed to support these efforts?

See answer to Question 14.

17. What safeguards can CMS use to ensure that beneficiaries are not unduly influenced to
enrollwith a particular DPC practice?

If Medicare allows the beneficiary to control these dollars via a personal account, DPC practices will need to market to these patients within their community. This is no different than is currently done under traditional Medicare programs. We do not see any unique moral hazards for DPC practices in this regard. If a patient is dissatisfied with their care or a DPC practice is not providing a good value for those dollars, the patient can transfer their care elsewhere. Market forces will correct poor business practices.

More than anything, beneficiaries who are allowed to independently choose their own DPC practice will have far more freedom than what occurs in the status quo to choose between providers and move freely within the healthcare system.

18. CMS wants to ensure that all beneficiaries have an equal opportunity to enroll with a
practice participating in a DPC model. How can CMS ensure that a DPC-participating
practice does not engage in activities that would attract primarily healthy beneficiaries
(“cherry picking”) or discourage enrollment by beneficiaries that have complex medical
needs or would otherwise be considered high risk (“lemon dropping”)? Whatadditional

beneficiary protections may be needed under a DPC model?

As DPC physicians, we are already taking care of people with complex medical needs. We see this everyday in our practices. Often we are more capable of meeting these patients needs because the extra time and communication the DPC model affords us. Also, patients with complex needs see a better value in our services. After nearly a decade, we have not seen the fear of “cherry picking” within DPC practices come to fruition; if anything, the opposite has occurred.

The only way we could forsee cherry-picking is with programs that reward or penalize outcomes or downstream utilization (clinical or financial). It’s one of the reasons we are skeptical of such approaches.

19. Giving valuable incentives to beneficiaries to influence their enrollment with a particular
DPC practice would raisequality of care, program cost, and competition concerns.
Providers and suppliers may try to offset the cost of the incentives by providing
medically unnecessary services or by substituting cheaper or lower quality
services. Also, the ability to use incentives may favor largerhealth care providers with
greater financial resources, putting smaller or rural providers at a competitive
disadvantage. What safeguards should CMS put in place to ensure that any beneficiary
incentives provided in a DPC model would not negatively impactquality of care,
program costs, and competition?

If this program is appropriately structured--with beneficiaries managing funds--we feel that DPC practices of all sizes and varieties will be on a level playing field. Beneficiaries themselves are in the best position to make a determination of which practice, including services and pricing, would best meet their needs. Many DPC practices do provide creative services, such as health coaching and educational events, as part of their practice. These type of novel approaches to improving patients’ lifestyle and health should not be restricted. However, providers participating in this program should continue to follow any and all rules about prohibiting “incentives” (gifts, etc.) to beneficiaries.

20. How can CMS protect beneficiaries from potential risks, such as identity theft, that could
arise in association with a potential DPC model?

This has not been an issue to date within the DPC model. If anything, a simple direct relationship reduces chances of fraud and identity theft vs. third-party billing practices.

Questions Related to Existing ACO Initiatives

21. For stakeholders that have experience working with CMS as a participant in one of our
ACO initiatives, how can we strengthen such initiatives to potentially attract more
physician practices and/or enable a greater proportion of practices to accept two-sided
financial risk? Whatadditional waivers would be necessary (e.g., to facilitate more
coordinated care in the right setting for a given patient or as a means of providing
regulatory relief necessary for purposes of testing the model)? Are there refinements
and/or additional provisions that CMS should consider adding to existing initiatives to
address some of the goals of DPC, as described above?

Most DPC physicians have opened independent practices at their own personal financial risk. They do this because existing payment models often do not allow them to provide high quality care and are often financially unsustainable. As DPC physicians we are able to curate great relationships with our patients. These relationships alone motivate us to provide better care and DPC model provides that opportunity. As caring professionals, we don’t believe that financial “risk” of bad outcomes provides any extra incentive to provide quality care. Thus, we expect very few DPC practices to have any interest in joining an ACO.

22. Different types of ACOs (e.g., hospital-led versus physician-led) may face different
challenges and have shown different levels of success in ACO initiatives to date. Would
a DPC model help address certain physician practice-specific needs or would physician
practices prefer refinements to existing ACO initiatives to better accommodate physician-led

Our members prefer a simplified, no attestation, low-cost model of care delivery. Direct payment from patients with the physician's time spent in direct care of the patients is what makes direct primary care revolutionary for patients and physicians.