On October 23, 2014, the Centers for Medicare & Medicaid
Services ("CMS") announced the Transforming Clinical Practice Initiative
("TCPI"), a new initiative aimed at supporting
clinicians in developing comprehensive quality improvement
strategies through collaborative learning networks. As part of the
TCPI, CMS will award cooperative agreement funding to facilitate
the development of two network systems—Practice
Transformation Networks and Support Alignment Networks. CMS
envisions Practice Transformation Networks as peer-based learning
networks that encourage clinicians in achieving practice
transformation through coaching, mentoring, and other assistance
initiatives. Support Alignment Networks would provide the
infrastructure to support Practice Transformation Networks and
clinician practices to help identify evidence-based practices and
scale them nationally throughout the health care delivery system.
Applicants may be funded for one of the two models only. CMS
intends to invest $840 million over the next four years to support
the TCPI to ensure that participating clinicians lead the efforts
in creating positive change for the health care industry as it
moves from volume-based to patient-centered quality care
models.
CMS offered examples of possible applicant initiative strategies,
including: (i) providing physicians with better access to patient
information; (ii) fostering patient communication with clinician
teams; (iii) improving care coordination across providers; and (iv)
utilizing electronic health records daily to analyze quality and
efficiency data.
We believe the Practice Transformation Networks, which will receive
most of the CMS funding (up to $670 million), will be of particular
interest to many of our provider network, hospital and health
system, and large physician practice group clients that have
already commenced clinician practice transformation efforts. CMS
anticipates awarding 35 cooperative agreement awards ranging from
$2 million to $50 million under the Practice Transformation Network
model in late spring 2015. CMS will award Practice Transformation
Network funding to successful applicants that propose compelling
means to assist clinicians in transforming their practices and
achieve the TCPI's goals, which include, without limitation:
(i) building an evidence base on practice transformation; (ii)
improving outcomes for Medicare, Medicaid, and CHIP beneficiaries;
(iii) reducing unnecessary hospitalizations and overutilization of
other services for beneficiaries; (iv) sustaining efficient care
delivery for beneficiaries; and (v) generating savings to the
federal government through reduced health program
expenditures.
Organizations with preexisting relationships with multiple
clinician practices (primary care and/or specialists) and
data-sharing capabilities are eligible to apply for Practice
Transformation Network funding. Importantly, CMS desires to
structure the Practice Transformation Network model to avoid
overlap with other CMS comprehensive practice transformation
initiatives, such as the Medicare Shared Savings Program and the
Pioneer ACO program; therefore, CMS indicates that it will not fund
proposals replicating models it is testing currently in other
initiatives.
Applications for both TCPI models are due no later than January 6,
2015. Although not required to do so, applicants are highly
encouraged to submit nonbinding letters of intent to apply by
November 20, 2014. There are a number of applicant eligibility
requirements and award restrictions under both TCPI models. Jones
Day will continue to monitor developments with the TCPI and is
available to provide assistance to interested parties in applying
for funding.
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