Letter to CMMI Regarding Global and Professional Direct Contracting Model Announcement

April 13, 2021


Elizabeth Fowler
Deputy Administrator and Director
Center for Medicare & Medicaid Innovation
U.S. Department of Health & Human Services
Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201

Dear Deputy Administrator Fowler:

The undersigned organizations, through the advocacy of the America’s Physician Groups Direct Contracting Coalition, submit this letter strongly urging you to provide an opportunity for prospective applicants to apply for the Global and Professional Direct Contracting Model (GPDC or the Model) by reopening the portal for applications and accepting new applicants for a January 1, 2022, start date.

The April 8 announcement from the agency indicated that it would not solicit any further applications beyond the initial April 1, 2021, cohort. This means that the second cohort, beyond those that deferred from an Implementation Period or first performance year applicants, will now be halted, thus depriving many of the undersigned organizations from participating in the program as planned for January 1, 2022.

We regard this unfortunate decision as a serious blow to the progress of the movement toward value-based care, perhaps the best hope for bringing higher quality and more affordable healthcare to all Americans. We have worked steadfastly for over ten years since the ACA was enacted to mature the risk model and the goal that was envisioned: a capitated payment model supported by robust quality improvement measurement incentives. Direct Contracting represents that goal, and having it curtailed now will do a major disservice to the country, the providers that have worked hard to make it succeed, and to the Medicare beneficiaries that depend upon it.

As you are well aware, the United States pays approximately twice as much per capita for healthcare as all other countries who are members of the international governmental Organization for Economic Co-operation and Development (OECD), and yet receives the lowest quality care in return of all the OECD countries. We are on the cusp of reversing those shameful statistics and the Direct Contracting model is the heart of that effort. To halt our progress, and potentially move us backward, seems almost unthinkable.

Potential participants have made substantial investments and conducted significant preparation in attempting to meet the requirements of participation for a January 2022 start date and to ensure that they are also able to embark upon the Model from the strongest vantage point possible because they regard it as America’s best hope in redesigning healthcare. While we fervently support the Administration’s efforts to expand coverage underway, the expansion of coverage does not lower costs or improve quality. The only known and proven way to improve quality and lower costs is bringing value into the delivery system and curtailing this effort is shortsighted.

CMMI has been an invaluable partner in the development of GPDC and we appreciate the investment the agency has made to ensure its success. Ending the application process early represents a great setback in the viability of the model and is a severe blow to beneficiaries who are expecting CMMI and the undersigned to fix and improve the American healthcare system especially during and after a pandemic crisis.

Thank you for your attention to the above comments. If you have any questions, please contact Valinda Rutledge, Executive Vice President of Federal Affairs at America’s Physician Groups, at vrutledge@apg.org.


America’s Physician Groups
Accountable Care Learning Collaborative
ACO Management Services
Agilon Health
American Academy of Home Care Medicine
Association Medical Group of Santa Clara County (SCCIPA)
Austin Regional Clinic
California Clinical Partners ACO
Catholic Health Physician Partners
Central Ohio Primary Care Physicians
Collaborative Health Systems
Elation Health
Hackensack Meridian Health
Hawaii IPA
Health Alliance ACO d/b/a GW Health Network
Iora Health
John Muir Health Physician Network
MSO of Puerto Rico, LLC
MultiCare Connected Care
Northeast Georgia Health System
NW Momentum Health Partners ACO
Ochsner Health
Palo Alto Foundation Medical Group
Pearl Health
Physicians of Southwest Washington
PIH Health
Pioneer Health Associates
Prisma Health
Privia Health
Prominence Health Plan
Prospect Medical Group/Prospect Medical Systems
Renaissance Physicians
Rush University System for Health
Silver State ACO
Signify Health
South Texas ACO Clinical Partners
Southwestern Health Resources Affordable Care Network
Tandigm Health
Texas Panhandle Clinical Partners
Texoma Clinical Partners
TriHealth Inc. in Cincinnati, Ohio


Please click here to download a copy of the letter.