Primary Care Review March – April 2025
Making Sense of Changes at the Federal Level
Every four years when administrations change, programs and policies are apt to change as well to anchor the priorities of the new administration. Of late though, the sheer number of executive orders and new agency pronouncements make it difficult to understand the moving pieces and implications. It is tempting to get lost in conjecture and opinion pieces. In this edition, we aim to stick to the facts with a population health and primary care lens in mind.
New Directions at the Center for Medicare and Medicaid Innovation (CMMI)
CMMI’s purpose is to serve as an innovation lab for promising new ways to use to test new payment and service delivery models. CMMI models are intended to improve care quality, lower cost, and promote patient-centered practices. With new administrations, we can expect to see new demonstrations introduced and expect to see announcements in the coming months.
CMS has assessed the current models and announced in a March 12th memo that several will end earlier than originally planned. This includes the Primary Care First (PCF) demonstration. PCF included an innovative primary care hybrid payment design alongside a set of expectations for participating practices. There are two cohorts of practices in the model – one that began in 2021 and the other that began in 2022.
Of the 145 Michigan PCF practices, many began participating in 2021 and would have completed the demonstration by year’s end anyway. As per the March 12th memo, now both cohorts will now complete their PCF participation by the end of this year. PCF practices will receive additional details from CMS with “timelines, technical assistance and other information regarding the wind-down and close-out.”
Another primary care-focused model, The Making Care Primary (MCP) demonstration, will also end early. MCP operated in eight states (Colorado, Massachusetts, Minnesota, New Jersey, New Mexico, New York, North Carolina, and Washington) and featured a shift over time toward fully prospective population-based payments.
Hearteningly, the memo states that “Primary care remains a foundational component of the Center’s strategy. The early termination of Primary Care First and Making Care Primary does not signal a retreat from the Center’s support of primary care providers, but rather a need to focus on different approaches that are consistent with the CMS Innovation Center’s statutory mandate and produce savings.”
Interestingly, one of the additional resources listed at the end of the March 12th memo was the Advanced Primary Care Management code bundles introduced in the Physician Fee Schedule in 2025.
The Innovation Center noted in a press release about the CMMI changes that they plan to announce a new strategy focused on “preventing disease through evidence-based practices, empowering people with information to make better decisions, and driving choice and competition.”
It appears that several other existing demonstration models will continue, including the Advancing All-Payer Health Equity Approaches and Development (AHEAD) Model which features global hospital budgets, primary care payment reform, and a focus on the total cost of care. AHEAD began in 2024 and will run through 2034. So far, the following areas have been selected to participate in AHEAD: Maryland, Connecticut, Hawaii, Vermont, New York (in five downstate counties: Bronx, Kings, Queens, Richmond, and Westchester) and Rhode Island.
We’ll be watching as new demonstration are announced, and you can be sure when they come out that we will cover them here.
CMS Rescinds Guidance on Health-Related Social Needs (HRSN) Changes
The new Deputy Administrator and Director at the Center for Medicaid and CHIP, Drew Snyder, issued an informational bulletin on March 4th rescinding some Health-Related Social Needs (HRSN) guidance issued during the Biden Administration. The first of the two rescinded documents was
named Coverage of Services and Supports to Address Health-Related Social Needs in Medicaid and the Children’s Health Insurance Program, and it outlined opportunities for addressing HRSN in the Medicaid and CHIP programs. The second rescinded document refined the original guidance.
As CMS assesses their path forward and evaluates policy alternatives, what is the impact on states with initiatives underway? The March 4rth 2025 bulletin notes that “CMS will consider states’ applications to cover these services and supports on a case-by-case basis to determine whether they satisfy federal requirements for approval under the applicable provisions of the Social Security Act and implementing federal regulations, without reference to the November 2023 and December 2024 informational bulletin or the HRSN Framework.”
It is helpful to remember that SDoH guidance was issued under the first Trump Administration and that this document is still active. This guidance aimed to “describe opportunities under Medicaid and CHIP to better address social determinants of health (SDOH) and to support states with designing programs, benefits, and services that can more effectively improve population health, reduce disability, and lower overall health care costs in the Medicaid and CHIP programs by addressing SDOH.”
In the last ten years, the quality and quantity of literature assessing SDoH and HRSN interventions has grown. Additionally, the transition from fee for service (FFS) to value-based care has become more imperative. This makes addressing SDoH and HRSN even more pressing. We are eager to watch for the new policies as they are unveiled.
Telehealth: Extended Once Again, This Time Until September 30, 2025
Once more, at almost the last moment, legislation was passed to prevent Medicare coverage of telehealth flexibilities and the hospital at home program from expiring. Coverage was scheduled to end on March 31, 2024, but on March 15th,
the President signed H.R.1968, the Full-Year Continuing Appropriations and Extensions Act of 2025. This action extends funding for many programs and permits continuing operations until the end of the fiscal year on September 30, 2025.
The continuing resolution extends many of the telehealth flexibilities that came were enacted at the start of the pandemic such as the originating site for Medicare telehealth providers and Medicare beneficiaries, removal of geographic requirements and expanded originating sites for telehealth services; expanded practitioners eligible to furnish telehealth services; and extended telehealth services for federally qualified health centers (FQHCs) and rural health clinics (RHCs). The resolution also delays the in-person requirements under Medicare for mental health services furnish through telehealth, including at rural health clinics and federally qualified health centers.
Michigan Multipayer Initiatives 