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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 MedicineNevada Care Connect
America’s Physician GroupsNOMS Healthcare
AMGANortheast Georgia Health Partners
Association of American Medical CollegesNortheast Georgia Physicians Group
Health Care Transformation Task ForceNorthern Michigan Health Network dba NPO-CIN
Medical Group Management AssociationNorthern Ohio Medical Specialists, LLC
National Association of ACOsNovello Physicians Organization
Premier healthcare allianceOak Street Health
Value Based Care CoalitionOchsner Health
360 HealthOhio’s Hospice
Acclivity Health SolutionsOhio’s Hospice of Dayton
Accountable Care Learning CollaborativeOhio Integrated Care Providers
AdventHealthOlympia Multispecialty Clinic
Advocate Aurora HealthOn Belay Health Solutions
AEGIS Medical GroupOncology Physicians Network
agilon healthOptima Medical
Akira MSOOptimizeVBC
Akos MD IPA LLCOptimus Healthcare Partners
Allied Pacific IPAOptum – Southwest Medical Associates
Amarillo Legacy Medical ACOOptum Care
American Multispecialty Group, Inc. dba Esse HealthPathways Health Partners
Americas DCEPearl Health
Answer Health (Grand Rapids, MI)Perfect Health (dba ConcertoCare)
AonPerfect Health DCE, LLC
APA ACO INCPhysicians Group of Southeastern Ohio (SE OH)
Apricus HealthPinehurst Medical Clinic (Pinehurst, NC)
Apricus Health NetworkPioneer Physicians Network
ArcadiaPioneer Physicians Network (Akron, OH)
Archway HealthThe Portland Clinic
Arizona Care NetworkPraxisCare Inc.
Arsenal Capital PartnersPreferred Primary Care Physicians (Pittsburgh, PA)
At Your Door Visiting Healthcare ServicesPremier Family Physicians (Austin, TX)
Atlantic Accountable Care OrganizationPrimary Care Alliance
Atrium Health Wake Forest BaptistPrimary Medical Group
Austin Regional ClinicPriMED
BabylonPriMED Physicians
Babylon Health & Babylon Medical GroupPrime Holdings
Banner HealthPrisma Health Upstate Network
Bloom HealthcarePritesh & Tarak, PA
BrightHealthProfessional Health care of Pinellas LLC
Brown & Toland PhysiciansProficient Health
CareAlliesProspect Medical Systems, Inc.
CareConnectMD DCE LLCProvidence Health and Services
CareDimensions LLCProvidence Medical Group, Inc.
Catholic Health Physician Partners ACOProvider Partners Health Plan
CentenePSW / NW Momentum Health Partners ACO
Central Ohio Primary CarePure Healthcare Inc.
ChenMedQ Point Health, LLC (dba Equality Health Direct)
CHESS Health SolutionsQuality Independent Physicians
Chronic Disease Management LLCQuincy Medical Group
Cityblock HealthRancho Family Medical Group
ClaraPriceRÃos Southwest MG
Collaborative Health SystemsReemo Health
Complete HealthReliance Hospice
Cone Health/Triad HealthCare NetworkRenovis Health
David Stansfield DO LLCRevere Health
DispatchHealthRios Southwest Medical Group
Dr Rios Medical GroupRobin Healthcare
Essentia HealthSaint Alphonsus Health Alliance
Executive Health of Coral Gables, LCSansum Clinic
Facey Medical GroupScripps Coastal Medical Group
FamilyCare Medical Group (Syracuse, NY)Sharp Community Medical Group
Fulshear Family MedicineSharp Community Medical Group Kenneth Roth
Genesis Health SystemSharp Rees-Stealy Medical Group
GeriNet Medical Associates Inc.SIMEDHealth
Greater Newport PhysiciansSouthwestern Health Accountable Care Network
Greater San Antonio Emergency PhysiciansSpace Coast Independent Practice Association, LLC
Hail Health ClusterSt. Joseph’s University Medical Center
HealthPartners ACOStarling Physicians (Hartford, CT)
Health Partners for the Elderly, LLCSummit Health
Hernando Pasco Primary Care, LLCSummit Medical Group, PLLC
Hospice of Central OhioSummit Reinsurance Services, Inc.
ilumedSutter Health
InnovaccerSutter Medicare Direct
Innovare Health AdvocatesTCPA
Integrated Care SolutionsTexas Health Resources
INTEGRIS HealthTexas Panhandle Clinical Partners ACO
Intermountain HealthcareTexasIPS
Iora Health/One MedicalTexoma ACO
IU HealthTMA
John Kuczynski MDTrella Health
John Muir Medical GroupTriad HealthCare Network
Kronos Health, PLLCTrinity Health
Lacey Medical ClinicTrinity Health Integrated Care Accountable Care Organization
Lakeview Healthcare SystemTucson La Clinica Familiar
Linscott Family PracticeTumwater Family Practice Clinic
Loyola Physician PartnersUHS/Prominence/ACO Management Services
LumerisUMass Memorial Health
Magnolia Clinica Medica FamiliarUnited Church Homes, Inc
MaineHealth Accountable Care OrganizationUnityPoint Accountable Care
Mary Washington Health Alliance LLCUniversity of Texas Southwestern Medical Center
MaxHealthUpStream Healthcare
McAuley Health Partners ACO, LLCValidate Health
MD Valuecare LLCValueH
Medcare Wellvana Pediatric CardiologyVancouver Clinic
Medical Home NetworkVicinia Health
MemorialCare Medical GroupVikas Desai MD PC
MercyOne PHSOVillage Medical at Home
Methodist Patient Centered ACOVillageMD
The MetroHealth SystemVillageMD Primary Providers ACO
MHN ACOVillageMD Arizona ACO
MMC Advisors LLCVillageMD Georgia ACO
Motog Inc. D/B/A St. Francois Medical CenterVillageMD Houston ACO
Mount Sinai Health SystemVillageMD Michigan ACO
MSO of Puerto Rico, LLCVillageMD New Hampshire ACO
MultiCare Health SystemWellvana Health
Muskingum Valley Health CenterWilems Resource Group
MyCare Pinellas, PAWilmington Health
Nath Holdings LLCZia ACO