Advocacy and Policy

2020 Policy and Advocacy Agenda

The Primary Care Collaborative (PCC) engages in team-based advocacy around policy and practice changes that promote robust primary care to achieve the quadruple aim. Our policy strategy is focused on increased investment in primary care through alternative payment models that enable PCMHs and other types of advanced primary care to provide integrated, higher-value care that connects to the community.

Evidence demonstrates – and our Executive Members and Supporters believe – that comprehensive primary care is a high-value intervention that transforms our health care system.  We work to empower patients through increased access to advanced primary care, and we support clinicians by encouraging team-based care and by empowering them to deliver the care that patients need and desire.  While we engage in a variety of issues, PCC’s current policy focus is on allocating the resources needed to achieve advanced primary care and ensuring patient access to such care.  More specifically: 

Investment in High-Value Primary Care that Improves Outcomes and Prevents Avoidable Costs

  • Promote a standardized way to measure and report primary care spending as a percentage of overall spend
  • Collect and disseminate evidence on the impact of adequately resourced primary care models 
  • Make the case for investment in high-value primary care alternative payment models that ensure support for comprehensive, coordinated, team-based primary care with proven results
Learn More
Map provided by Milbank Memorial Fund

Support Payer and Purchaser Innovations that Promote Access to Primary Care

  • Shape the legislative/regulatory environment for value-based models to ensure that access to high-value primary care is core to benefit design. (Recent studies show a decline in patient use of such care – perhaps due to financial barriers.)
  • Collect and disseminate evidence linking access to high-performing primary care to improvements in health, affordability, and workforce outcomes
  • Promote the selection of a primary care provider at enrollment, the removal of financial barriers to primary care through the reduction of copayments and deductibles for high-value primary care services, and access to Patient-Centered Medical Homes

Primary Care Investment Workshop

Slides and Recap of PCPCC's Nov 9, 2018 Workshop on Primary Care Investment

In addition to these two advocacy-related focus areas, PCC will continue to convene thought leaders, develop programming, and educate in areas core to its work of strengthening advanced primary care models, including practice-level behavioral health integration, team-based and collaborative care, and patient and family engagement.

Learn more about these efforts as they develop at or reach out us at [email protected]

PCC has long led the effort to transform primary care into a more integrated, team-based model – captured through the Patient-Centered Medical Home (PCMH).   While these models are becoming widely adopted, they rarely have enough resources nor the flexibility in payment structure to meet the goals laid out by the Shared Principles of Primary Care.   As shown in PCC’s Primary Care Innovations Map, there are exciting demonstrations, plans, and regions that are exceptions to this rule, but clinicians, on a national level, continue to struggle to realize the vision for primary care embodied in the Shared Principles.

Recent Policy and Advocacy Activity

July 1, 2020

Below are brief summaries of the efforts of five states to support primary care, including efforts that COVID-19 has prompted given the financial challenges that the pandemic has wrought.

North Carolina
As this newsletter is disseminated, PPC applauds Blue Cross and Blue Shield of North Carolina’s recent announcement to support independent primary care practices financially as they weather the COVID-19 storm. Financial support will be in the form of per BCBSNC beneficiary payments estimated to make the 2020 practice revenue equivalent to 2019 revenue. To be eligible, practices must commit to remaining independent and joining one of BCBSNC’s value-base primary care or ACO payment models by 2021, which means joining its Blue Premier network payment model. For more information, see Chief Medical Officer Rahul Rajkumar’s post.

In late 2019, Massachusetts Gov. Charlie Baker released comprehensive legislation that would incentivize health plans and providers to devote more resources to primary care and behavioral health services. It builds on Massachusetts’ comprehensive approach to managing growth in the total cost of care and its cost benchmarking process (see below). While the bill has not advanced in 2020, it remains a post-COVID-19 priority for the governor. See the summary.

In June 2020, Delaware issued a “preliminary look” at aggregate state healthcare spending under its state healthcare spending benchmark, which was established by executive order of Governor John Carney in 2018. The report, which uses data submitted by insurers, includes an attempt to measure primary care spending and will provide an opportunity for primary care advocates to dig deeper into the numbers and continue to educate stakeholders.

There were a number of recent efforts to support and further primary care, including those driven by employers, a health plan and nurse practitioners.    

The Pacific Business Group on Health teamed up with the California Medical Association on a proposal called the Care for Californians Initiative that would require health plans to use unspent premiums already collected from employers and consumers to pay primary care providers emergency prospective payments in 2020 and 2021.

Blue Shield of California announced an ambitious Health Reimagined initiative that will use value-based payment models and take a “holistic” approach to care while leveraging digital tools and efforts to reduce administrative burdens on physicians.

Legislation was introduced early in 2019 to give nurse practitioners expanded scope to practice independently. It passed out of the state assembly before stalling in the state senate but remains a priority for advocates of care for underserved communities, such as the California Health Care Foundation.  

The Milbank Memorial Fund sponsored an issue brief from the team leading Maryland’s Primary Care Program (MDPCP). A multi-payer model that is integrated with Maryland’s broader all-payer “total cost of care model,” the MDPCP is a comprehensive approach that builds on learnings from the CMMI Comprehensive Primary Care (CPC) and CPC+ models. Maryland’s investments in health information exchange and data collection will also support MDPCP.

If we missed your state and an item you want to share, please reach out to Alyssa Neumann at [email protected]

(republished from PCC's summer 2020 newsletter)

July 1, 2020

The PCC has been dedicated to documenting the plight of primary care practices and patients during the historic COVID-19 pandemic as well as leading multi-stakeholder strategies and advocacy to save and strengthen primary care right now.

  • We have amplified and lifted up key messages of the #SavePrimaryCare campaign, including disseminating our letter to Department of Health and Human Services Secretary Alex Azar widely and leveraging our social media presence. Feel free to use our letter to write your own letter to urge Azar to make a targeted allocation from the CARES Act provider relief fund for primary care practices.
  • We redoubled our outreach to congressional offices and HHS officials to highlight the staggering $15 billion figure - the recent estimate from researchers at Harvard Medical School’s Center for Primary Care of revenue losses that primary care practices will collectively sustain in 2020.  The PCC is grateful for the work of Sanjay Basu, MD, PhD, and colleagues and the willingness of Health Affairs to fast-track release of this careful, conservative estimate of financial losses by primary care practices sustained collectively and at the practice level. Most alarming, the study estimates losses could grow to $19 billion if the predicted second-infection wave comes in the fall, and losses could reach $39 billion if HHS retreats from the temporary emergency-based telehealth payment policies.  

Together with our leadership, the PCC is beginning to compile and prioritize which of the many regulatory waivers we would like to see become permanent to accelerate primary care transformation and payment-reform efforts. We signed on to a letter led by HIMSS to signal our interest in making some of the Medicare telehealth waivers permanent.

Temporary Federal Waivers of Payment, Other Rules

While the federal response to COVID-19 has been mixed at best, HHS leadership has taken extraordinary steps to waive regulations in order to give flexibility to the healthcare delivery system to more readily serve patients safely with virtual visits. With authorization from Congress, restrictive Medicare telehealth rules have been lifted, payment parity established, and telephonic visits made eligible for reimbursement. For more information about these changes and their contingency on different federal emergency declarations, see McDermott Consulting’s helpful summary.

Waivers Support Team-Based Care, Virtual Care

The broad sweep of regulatory waivers by federal and state authorities during the pandemic cannot be understated. The Alliance for Connect Care has been tracking them. The regulatory waivers encompass supervision requirements, whether a relationship has been “established” before treating a patient via telehealth, which clinicians are eligible to provide treatment and bill for telehealth services, how methadone is dispensed to patients in treatment for opioid addiction, and whether a licensed physician can treat a patient residing or staying across state lines. These are just a few of the regulations that have been waived by federal and state officials. Many of these regulations inhibit the development of team-based care and the ability of practices to innovate and optimize the team’s effectiveness and efficiency. Some are not patient-centered and rather paternalistic.

The PCC looks forward to hearing from our membership about how to leverage the possibilities created by these waivers if they were to be made permanent, while also including guardrails that ensure accountability for quality,  appropriateness of care and patient privacy.

(republished from PCC's summer 2020 newsletter)

June 29, 2020

PCC is among the 340 organizations that sent a letter today urging congressional leaders to make telehealth flexibilities created during the COVID-19 pandemic permanent. Organizations signing this multi-stakeholder letter include national and regional organizations representing a full range of healthcare stakeholders and all 50 states, the District of Columbia, and Puerto Rico.

Congress quickly waived statutory barriers to allow for expanded access to telehealth at the beginning of the COVID-19 pandemic, providing federal agencies with the flexibility to allow healthcare providers to deliver care virtually. If Congress does not act before the COVID-19 public health emergency expires, current flexibilities will immediately disappear.

Therefore, 340 stakeholders have sent a powerful message to Congress outlining the immediate actions necessary to ensure CMS has the authority to continue to make telehealth services available once the national health emergency is rescinded:

  • Remove obsolete restrictions on the location of the patient to ensure that all patients can access care at home and other appropriate locations;
  • Maintain and enhance HHS authority to determine appropriate providers and services for telehealth;
  • Ensure Federally Qualified Health Centers and Rural Health Clinics can furnish telehealth services after the public health emergency; and
  • Make permanent Health and Human Services (HHS) temporary waiver authority for future emergencies.

While federal agencies can address some of these policies going forward, the Centers for Medicare and Medicaid (CMS) does not have the authority to make changes to Medicare reimbursement policy for telehealth under the outdated Section 1834(m) of the Social Security Act. Following these priorities will allow CMS to build on the experience gained during the pandemic and expand access to telehealth in a thoughtful, data-driven way.

Read the letter to Congress, including the list of 340 stakeholders

June 12, 2020

Six former leaders of the Centers for Medicare and Medicaid Services sent a joint letter June 10 to congressional leaders about the role of payment and regulatory flexibility in responding to the COVID-19 pandemic and addressing serious challenges in access to care and disparities in health outcomes in the pandemic and beyond.

In the letter, the leaders, who have served in the roles of CMS Administrator, Acting CMS Administrator, and HCFA Administrator, proposed three steps to support clinicians and other health care providers in the COVID-19 response and to build on reforms for the future. The letter was addressed to Speaker of the House Nancy Pelosi; House Minority Leader Kevin McCarthy; Senate Majority Leader Mitch McConnell; and Senate Minority Leader Chuck Schumer.

Read the full letter.

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