Role of POs as CPC+ Partners

In CPC+, CMS contracts directly with each CPC+ participating practice across the nation.  In Michigan, Physician Organizations (POs) support practices and as such are valuable allies in advancing primary care efforts.  As a multipayer team, we have discussed the important role of POs in Michigan with CMS , and our CMS partners provided clarification on what POs can and cannot do in the CPC+ model. This was documented in a July 21, 2017 multipayer correspondence with CMS where they noted that:

  • A PO rep cannot be the primary or secondary CMS CPC+ contact for the practice, but can be listed as a third or fourth contact by the practice.
  • A PO cannot fulfill practice requirements on behalf of the practice (e.g., cannot run a systems-level Patient and Family Advisory Council (PFAC) to meet the practice-level PFAC requirement) but can support practice implementation of a requirement (e.g., outline an approach and common tools for application across practices, etc.).
  • The PO can be the employer of care managers, providing that the care manager is embedded as practice team member and actively practicing at the practice site.
  • The PO rep can be a speaker at a TMF event or other CPC+ learning opportunity.