Update: The Center for Medicare and Medicaid Innovation (Innovation Center) is excited to announce that 53 Direct Contracting Entities (DCEs) are participating in the first Performance Year (PY2021) of the GPDC Model, which runs from April 1, 2021 through December 31, 2021. A list of all PY2021 participating DCEs (including DCEs continuing participation from the Implementation Period and DCEs beginning participation in PY2021) is available here. The Innovation Center no longer intends to solicit applications from new organizations interested in participating in the GPDC Model beginning on January 1, 2022. Organizations that applied in the previous application cycles—either for the Implementation Period or PY2021—and deferred their start date to January 1, 2022 will be permitted to start participating in the model as planned on January 1, 2022, as long as they continue to meet model requirements. However, at this time the Innovation Center will not be accepting new applications from any new organizations, including organizations interested in participating in the model as a Medicaid Managed Care Organization-based (MCO-based) DCE.
The Global and Professional Direct Contracting (GPDC) Model is a set of two voluntary risk-sharing options aimed at reducing expenditures and preserving or enhancing quality of care for beneficiaries in Medicare fee-for-service (FFS), also known as Original Medicare. The goals in designing the GPDC Model include:
- Create opportunities for a broad range of organizations to participate with the Centers for Medicare & Medicaid Services (CMS) in testing the next evolution of risk-sharing arrangements to produce value and high quality health care.
- Build on lessons learned from initiatives involving Medicare Accountable Care Organizations (ACOs), such as the Medicare Shared Savings Program (MSSP) and the Next Generation ACO (NGACO) Model. It also includes innovative ideas from Medicare Advantage (MA) and private sector risk-sharing arrangements.
The risk-sharing options are anticipated to appeal to a broad range of physician practices and other organizations because they are expected to reduce burden, support a focus on beneficiaries with complex, chronic conditions, and encourage participation from organizations that have not typically participated in Medicare FFS or CMS Innovation Center models. These health care organizations may offer optional incentives and benefit enhancements to Medicare beneficiaries who are aligned to a participating Direct Contracting Entity. Medicare beneficiaries will not lose any of their benefits and can continue to see any health care provider they choose.
The GPDC Model was previously called the Direct Contracting Model for Global and Professional Options. As part of the Direct Contracting initiative, CMS has also announced the Geographic Direct Contracting Model, which is currently under review. Additional information is available on the Geographic Direct Contracting Model web page.
CMS has determined that, beginning April 1, 2021, the anti-kickback statute safe harbor for CMS-sponsored model arrangements (42 CFR § 1001.952(ii)(1)) is available to protect certain DCE financial arrangements between or among the DCE, one or more DC Participant Providers, one or more Preferred Providers, or a combination thereof, provided that such arrangements comply with the requirements set forth in Section 3.04.M.1 of the GPDC Model Performance Period Participation Agreement (“Participation Agreement”). (Unless otherwise specified, capitalized terms have the meaning set forth in the Participation Agreement.)
Further, CMS has determined that, beginning April 1, 2021, the anti-kickback statute safe harbor for CMS-sponsored model patient incentives (42 CFR § 1001.952(ii)(2)) is available to protect certain in-kind patient incentives and Beneficiary Engagement Incentives furnished by a DCE, DC Participant Provider, or Preferred Provider to a Beneficiary or DC Beneficiary (as applicable), provided that such incentives are furnished in a manner that complies with the requirements set forth in Section 5.08.B of the Participation Agreement.
View the GPDC Model Goals (PDF)
Organizations have expressed interest in a model that draws upon private sector approaches to risk-sharing arrangements and payment with reduced administrative burden commensurate with the level of downside risk. The risk-sharing options available under GPDC take significant steps toward providing a prospectively determined revenue stream for model participants. Compared to other initiatives, the GPDC Model also includes a reduced set of quality measures that focuses more on outcomes and beneficiary experience than on process. By providing flexible options with regard to, for example, risk-sharing arrangements, financial protections, and benefit enhancements, CMS expects that participation in the GPDC Model will be attractive to former NGACO participants, as well as organizations that have experience with risk-based contracts in MA, but have not to date participated in Medicare FFS or CMS Innovation Center models.
The GPDC Model is expected to increase beneficiaries’ access to innovative, affordable care while maintaining all original Medicare benefits. A model participant in the GPDC Model, a DCE, may offer benefit enhancements and beneficiary engagement initiatives to beneficiaries with no requirement that beneficiaries accept these benefits or services. Relative to prior CMS initiatives, the GPDC Model places an emphasis on voluntary alignment, empowering beneficiaries to choose the health care providers with whom they want to have a care relationship. The GPDC Model also aims to improve beneficiaries’ experience of care by reducing administrative burdens on practitioners, so that they can focus on what is most important: spending time with patients.
The Model's goals are to:
- Transform risk-sharing arrangements in Medicare FFS by offering both capitated and partially capitated population-based payments that move away from traditional FFS.
- Broaden participation in CMS Innovation Center models by allowing model participation by organizations new to Medicare FFS, such as physician-managed organizations that have historically operated exclusively in the MA program, and Medicaid MCOs that provide Medicaid benefits for full-benefit dually eligible beneficiaries.
- Empower beneficiaries to engage in their health care through voluntary alignment and potential benefit enhancements and beneficiary engagement incentives.
- Reduce provider burden to meet health care needs effectively, through for example, a smaller set of core quality measures.
A key aspect of the GPDC Model is providing new opportunities for a variety of different health care organizations (Direct Contracting Entities or DCEs) to participate in value-based care arrangements in Medicare FFS. Under GPDC, there will be four types of DCEs with different characteristics and operational parameters. These four types of DCEs are:
- Standard DCEs - DCEs composed of organizations that generally have experience serving Medicare FFS beneficiaries, including Medicare-only and also dually eligible beneficiaries, who are aligned to a DCE through voluntary alignment or claims-based alignment. These organizations may have previously participated in section 1115A shared savings models (e.g., Next Generation ACO Model and Pioneer ACO Model) and/or the Shared Savings Program. Alternatively, new organizations, composed of existing Medicare FFS providers and suppliers, may be created in order to participate in this DCE type. In either case, clinicians participating within these organizations would have substantial experience serving Medicare FFS beneficiaries.
- New Entrant DCEs - DCEs composed of organizations that have not traditionally provided services to a Medicare FFS population and who may rely primarily on voluntary alignment, at least in the first few performance years of the model. Claims-based alignment will also be utilized.
- High Needs Population DCEs - DCEs that serve Medicare FFS beneficiaries with complex needs, including dually eligible beneficiaries, who are aligned to the DCE through voluntary alignment or claims-based alignment. These DCEs are expected to use a model of care designed to serve individuals with complex needs, such as the one employed by the Programs of All-Inclusive Care for the Elderly (PACE), to coordinate care for their aligned beneficiaries.
- MCO-based DCEs - DCEs that manage the Medicare FFS expenditures of full-benefit dually eligible beneficiaries who receive Medicaid benefits though a Medicaid Managed Care Organization (MCO). Each MCO-based DCE will be a Medicaid MCO (as defined in Section 1903(m) and 42 CFR § 438.2) or a legal entity affiliated with such an MCO under common ownership (i.e., the legal entity either owns the MCO or there is at least partial ownership of both the legal entity and the MCO by the same parent organization, where that parent organization also has a controlling interest). These MCOs already bear financial risk for the costs of furnishing Medicaid benefits under the Medicaid managed care contract, so by accepting Medicare FFS risk under GPDC, the MCO – or the legal entity affiliated with the MCO, if applicable – will take greater accountability for total cost of care for aligned dually eligible beneficiaries (i.e., accountability for both Medicaid and Medicare Parts A & B services, excluding any services carved out of the Medicaid benefit by the state). The Innovation Center will not be soliciting applications for this DCE type at this time as this DCE type is currently under review.
View How to Achieve the GPDC Model Goals (PDF)
There are two voluntary risk-sharing options under the GPDC Model:
- Professional offers the lower risk-sharing arrangement—50% savings/losses—and provides Primary Care Capitation, a capitated, risk-adjusted monthly payment for primary care services provided by DC Participant Providers and those Preferred Providers that have agreed to participate in capitation (by accepting FFS claims reductions and agreeing to receive compensation from the DCE).
- Global offers the highest risk sharing arrangement—100% savings/losses—and provides two payment options: Primary Care Capitation (described above) or Total Care Capitation, a capitated, risk-adjusted monthly payment for all covered services provided by DC Participant Providers and those Preferred Providers that have agreed to participate in capitation (by accepting FFS claims reductions and agreeing to receive compensation from the DCE).
The Professional and Global options aim to attract a range of health care providers operating under a common governance structure, with attention given to advancing primary care as a means to better managing health care overall. CMS expects that the use of voluntary alignment will attract organizations that previously were ineligible to participate in Medicare ACO models and the Medicare Shared Savings Program because of their previously low volume of Medicare FFS beneficiaries, such as organizations that currently operate in the MA program. Each risk-sharing option includes features aimed at encouraging organizations focused on care for patients with complex, chronic conditions, and seriously ill populations to participate.
The GPDC Model began in 2020 with an initial implementation period for organizations that wanted to align beneficiaries to meet the minimum beneficiary requirements prior to the start of the first performance year. Six performance years will follow, beginning in April 2021.
The GPDC Model will be an Advanced Alternative Payment Model (APM) starting in its first performance year (PY2021).
The application period for Performance Year 2021 (PY2021) has closed. The Innovation Center no longer intends to solicit applications from new organizations interested in participating in the GPDC Model beginning on January 1, 2022. Organizations that applied in the previous application cycles—either for the Implementation Period or PY2021—and deferred their start date to January 1, 2022 will be permitted to start participating in the model as planned on January 1, 2022, as long as they continue to meet model requirements. However, at this time the Innovation Center will not be accepting new applications from any new organizations, including organizations interested in participating in the model as a Medicaid Managed Care Organization-based (MCO-based) DCE.
CMS may entertain additional application rounds for future years for all DCE Types and risk-sharing options.
Information for Interested Stakeholders
CMS will be hosting webinars for GPDC; please continue to check this site for updates. If you are interested in receiving CMS Innovation Center updates, including about GPDC, subscribe to the CMS Innovation Center listserv.
- Webinar: Direct Contracting Model Options - Professional and Global Options Overview (12/11/2019)
- Webinar: Direct Contracting Model Options - Benefit Enhancements (12/18/2019)
- Webinar: Direct Contracting Model Options - Payment Part One (1/15/2020)
- Webinar: Direct Contracting Model Options - Payment Part Two (1/22/2020)
- Call: Direct Contracting Model Options - COVID-19 Flexibilities (6/4/2020)
- Webinar: Direct Contracting Model Options - Financial Methodology (9/18/2020)
- Webinars: Direct Contracting Model Options - Overview Series
- Webinar: Direct Contracting Model Options - Professional and Global Options Financial Methodology Reconciliation (12/17/2020)
If you are interested in receiving additional information and updates specifically about the GPDC Model, please subscribe to the GPDC Model listserv.
For any questions, please email the GPDC Model team at DPC@cms.hhs.gov.
- Request for Applications (RFA) (PDF)
- Frequently Asked Questions - April 2021 (PDF)
- Implementation Period Participants (PDF)
- Second Implementation Period (IP2) Participants (PDF)
- PY2021 Participants (PDF)
- Model Overview for State Insurance Regulators
- GPDC Model Archived Materials
- Financial Frequently Asked Questions - April 2021 (PDF)
- PY2022 DC/KCC Rate Book (XLS)
- PY2022 DC/KCC Rate Book Development (PDF)
- PY2022 DC/KCC Risk Adjustment (PDF)
- PY2022 Financial Operating Guide Overview (PDF) - Updated 12/1/2021
- PY2022 Capitation and Advanced Payment Mechanisms (PDF)
- PY2022 Financial Reconciliation Overview (PDF)
- PY2022 Quality Measurement Methodology (PDF) - Updated 12/1/2021
- PY2021 Financial Papers (Archived Materials)