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The Honorable Xavier Becerra
U.S. Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, DC 20201

Re: Continuing the Direct Contracting Model

Dear Secretary Becerra:

The undersigned organizations write to urge you to not cancel the Global and Professional Direct Contracting Model (GPDC) and instead make necessary refinements to improve the model in support of patients and providers. Direct Contracting is an accountable care model for traditional Medicare. Stopping Direct Contracting is bad policy and would undermine our health system’s move to value-based payment models, which is sorely needed to achieve the triple aim of better patient satisfaction, higher quality care, and more affordable care. Traditional Medicare patients’ care would be worse off without the benefits and quality of care provided by Direct Contracting Entities (DCEs). 

Cancelling Direct Contracting would additionally undermine the work of the Center for Medicare and Medicaid Innovation (Innovation Center) and the Centers for Medicare & Medicaid Services (CMS). The Innovation Center was a critical part of the Affordable Care Act and is an instrument to test value-based payment models that make care more affordable while also improving quality of care. Much has been learned over its first decade of work. Should this model be abruptly ended, health care providers would be terminated from value-based payment participation without warning, making them far less likely to invest and participate in future CMS payment models. This would be particularly unfair for the dozens of Accountable Care Organizations (ACOs) that moved into Direct Contracting after the December 2021 conclusion of the Next Generation ACO Model, a successful provider-led payment model launched under then President Obama’s administration. The Innovation Center work and the shift to value-based care has been bipartisan and should remain that way. 

Rather than cancelling Direct Contracting, a better option is to adjust the model, which the CMS Innovation Center can quickly do. Fix, don’t end, the Direct Contracting Model. For example, you can limit participation to certain types of DCEs, such as provider-led DCEs, and place additional guardrails and add more beneficiary protections. A rebranding and name change would also help communicate how this model is part of the evolution to accountable care. There’s still time to make these adjustments this year. The Innovation Center would also benefit from a public announcement that the Geographic Direct Contracting Model, which is being confused with the very different Global and Professional options, is stopped entirely. 

Many of the recent criticisms against the model are misleading and flat out false. Traditional Medicare patients maintain their freedom of choice to see any willing provider. They keep all of their rights and protections, and in fact, get more benefits and lower cost care through the model. There are no networks or prior authorization. DCEs must inform patients of their assignment to a DCE. This is not the end of traditional Medicare, as advocates have falsely claimed, but is a way to provide additional beneficiary and provider tools as part of a whole-person care approach.  

Furthermore, Direct Contracting is part of the CMS Innovation Center’s efforts to help underserved populations, a focus which should be built upon through program modifications. CMS officials have stated that DCEs have proportionately more providers in communities with high numbers of low-income and minority patients. The model in fact incentivizes care for sicker, high-needs patients. Lessons learned from the model could be applied to other payment models. Canceling Direct Contracting would hurt our health system’s efforts to address health disparities. 

The organizations listed below have worked tirelessly, most recently in the face of a global pandemic, to move towards a health care delivery and payment system that emphasizes quality and value. During the pandemic, DCEs have been able to use care coordinators, telehealth, preventive care, and other waivers to keep patients healthy in the face of COVID. This work has been done despite challenges such as staff shortages, clinician burnout and grave financial struggles. Their work should be commended, not vilified. 

Direct Contracting is a needed high-risk, value-based payment model designed to improve patient care. Please keep the model and make adjustments as needed or else we 


AMDA-The Society for Post-Acute and Long-Term Care Medicine Nevada Care Connect
America’s Physician Groups NOMS Healthcare
AMGA Northeast Georgia Health Partners
Association of American Medical Colleges Northeast Georgia Physicians Group
Health Care Transformation Task Force Northern Michigan Health Network dba NPO-CIN
Medical Group Management Association Northern Ohio Medical Specialists, LLC
National Association of ACOs Novello Physicians Organization
Premier healthcare alliance Oak Street Health
Value Based Care Coalition Ochsner Health
360 Health Ohio's Hospice
Acclivity Health Solutions Ohio's Hospice of Dayton
Accountable Care Learning Collaborative Ohio Integrated Care Providers
AdventHealth Olympia Multispecialty Clinic
Advocate Aurora Health On Belay Health Solutions
AEGIS Medical Group Oncology Physicians Network
agilon health Optima Medical
Akira MSO OptimizeVBC
Akos MD IPA LLC Optimus Healthcare Partners
Allied Pacific IPA Optum - Southwest Medical Associates
Amarillo Legacy Medical ACO Optum Care
American Multispecialty Group, Inc. dba Esse Health Pathways Health Partners
Americas DCE Pearl Health
Answer Health (Grand Rapids, MI) Perfect Health (dba ConcertoCare)
Aon Perfect Health DCE, LLC
APA ACO INC Physicians Group of Southeastern Ohio (SE OH)
Apricus Health Pinehurst Medical Clinic (Pinehurst, NC)
Apricus Health Network Pioneer Physicians Network
Arcadia Pioneer Physicians Network (Akron, OH)
Archway Health The Portland Clinic
Arizona Care Network PraxisCare Inc.
Arsenal Capital Partners Preferred Primary Care Physicians (Pittsburgh, PA)
At Your Door Visiting Healthcare Services Premier Family Physicians (Austin, TX)
Atlantic Accountable Care Organization Primary Care Alliance
Atrium Health Wake Forest Baptist Primary Medical Group
Austin Regional Clinic PriMED
Babylon PriMED Physicians
Babylon Health & Babylon Medical Group Prime Holdings
Banner Health Prisma Health Upstate Network
Bloom Healthcare Pritesh & Tarak, PA
BrightHealth Professional Health care of Pinellas LLC
Brown & Toland Physicians Proficient Health
CareAllies Prospect Medical Systems, Inc.
CareConnectMD Providence
CareConnectMD DCE LLC Providence Health and Services
CareDimensions LLC Providence Medical Group, Inc.
Catholic Health Physician Partners ACO Provider Partners Health Plan
Centene PSW / NW Momentum Health Partners ACO
Central Ohio Primary Care Pure Healthcare Inc.
ChenMed Q Point Health, LLC (dba Equality Health Direct)
CHESS Health Solutions Quality Independent Physicians
Chronic Disease Management LLC Quincy Medical Group
Cityblock Health Rancho Family Medical Group
ClaraPrice RÃos southwest MG
Collaborative Health Systems Reemo Health
Complete Health Reliance Hospice
Cone Health/Triad HealthCare Network Renovis Health
David Stansfield DO LLC Revere Health
DispatchHealth Rios Southwest Medical Group
Dr Rios Medical Group Robin Healthcare
Essentia Health Saint Alphonsus Health Alliance
Executive Health of Coral Gables, LC Sansum Clinic
Facey Medical Group Scripps Coastal Medical Group
FamilyCare Medical Group (Syracuse, NY) Sharp Community Medical Group
Fulshear Family Medicine Sharp Community Medical Group Kenneth Roth
Genesis Health System Sharp Rees-Stealy Medical Group
GeriNet Medical Associates Inc. SIMEDHealth
Greater Newport Physicians Southwestern Health Accountable Care Network
Greater San Antonio Emergency Physicians Space Coast Independent Practice Association, LLC
Hail Health Cluster St. Joseph's University Medical Center
HealthPartners ACO Starling Physicians (Hartford, CT)
Health Partners for the Elderly, LLC Summit Health
Hernando Pasco Primary Care, LLC Summit Medical Group, PLLC
Hospice of Central Ohio Summit Reinsurance Services, Inc.
ilumed Sutter Health
Innovaccer Sutter Medicare Direct
Innovare Health Advocates TCPA
Integrated Care Solutions Texas Health Resources
INTEGRIS Health Texas Panhandle Clinical Partners ACO
Intermountain Healthcare TexasIPS
Iora Health/One Medical Texoma ACO
IU Health TMA
John Kuczynski MD Trella Health
John Muir Medical Group Triad HealthCare Network
KPN TriHealth
Kronos Health, PLLC Trinity Health
Lacey Medical Clinic Trinity Health Integrated Care Accountable Care Organization
Lakeview Healthcare System Tucson La Clinica Familiar
Linscott Family Practice Tumwater Family Practice Clinic
Loyola Physician Partners UHS/Prominence/ACO Management Services
Lumeris UMass Memorial Health
Magnolia Clinica Medica Familiar United Church Homes, Inc
MaineHealth Accountable Care Organization UnityPoint Accountable Care
Mary Washington Health Alliance LLC University of Texas Southwestern Medical Center
MaxHealth UpStream Healthcare
McAuley Health Partners ACO, LLC Validate Health
MD Valuecare LLC ValueH
Medcare Wellvana Pediatric Cardiology Vancouver Clinic
Medical Home Network Vicinia Health
MemorialCare Medical Group Vikas Desai MD PC
MercyOne PHSO Village Medical at Home
Methodist Patient Centered ACO VillageMD
The MetroHealth System VillageMD Primary Providers ACO
MHN ACO VillageMD Arizona ACO
MMC Advisors LLC VillageMD Georgia ACO
Motog Inc. D/B/A St. Francois Medical Center VillageMD Houston ACO
Mount Sinai Health System VillageMD Michigan ACO
MSO of Puerto Rico, LLC VillageMD New Hampshire ACO
MultiCare Health System Wellvana Health
Muskingum Valley Health Center Wilems Resource Group
MyCare Pinellas, PA Wilmington Health
Nath Holdings LLC Zia ACO