Comment Letter: Primary Cares Initiative Direct Contracting Model

June 18, 2019

Today, the MLTSS Association submitted comments to CMMI regarding the opportunity for Medicaid Managed Care Organizations (MCOs) to participate in the Direct Contracting (DC) model for the population of individuals fully eligible for both Medicare and Medicaid, announced as part of the Primary Cares Initiative.  The Association’s members are interested in the potential this model offers to establish Direct Contracting Entities (DCEs) that can align and coordinate Medicare benefits for dually-eligible enrollees who remain in fee-for-service (FFS) Medicare.  While the potential of this approach is intriguing, the Association also raised several questions about how this model would work and offered suggestions about design features that could have a substantial impact on the uptake of this approach and on its success in achieving its aims.

Read the Association’s full comments here.