Last month, the Center for Medicare and Medicaid Innovation (CMMI) unveiled a pilot, value-based Medicare delivery and payment model called the Geographic Direct Contracting model, or “Geo.” This pilot is set to launch in January 2022, and will allow different types of Medicare providers, including health plans and provider groups, to apply to become “direct contracting entities” (“DCEs”) that will manage the health care needs of Medicare enrollees across an entire geographic region. While we at the Center are overall supportive of testing new models to determine if costs can be reduced while maintaining or improving the quality of care, we are concerned about potential adverse impacts this model may have on individuals dually eligible for Medicare and Medicaid.

The “Geo” model has raised concerns from both patient advocacy groups and provider advocacy groups for several reasons. From the industry perspective, there’s concern that the introduction of a new model, when there are already many others in place that have yet to be fully evaluated, may cause unnecessary competition and complexity in the market. From the patient perspective, there are concerns that this complexity may cause consumer confusion and adversely impact access to care. For example, all Medicare enrollees will be placed into the “Geo” model without the ability to opt-out and can only switch between DCE available in their region quarterly or annually. This policy applies to individuals dually-eligible for Medicaid and Medicare, many of whom have highly complex or specific health needs. The fact that dually-eligible individuals will be automatically placed into this model and unable to disenroll when they want, when a different health plan option or provider may better fit their needs, raises significant concerns about the impact this model will have on their care.

One potential benefit of the “Geo” model is that since health care providers will be responsible for the health and costs of patients in an entire geographic region, they’ll be uniquely positioned to address the social and economic determinants of health afflicting that region. For example, if a certain city has inadequate transportation, a lack of affordable housing or poor air quality, providers now have strong incentives to take these issues into account and commit resources to address them, since they will likely affect all of their patients in some way. As more information and the application process for the “Geo” model unfolds throughout this year, as well as other types of direct contracting entity models that impact dual eligibles, such as the Medicaid Managed Care Organization (MCO)-based DCE, the Center will be monitoring for opportunities for meaningful consumer engagement and ways that these models can keep consumer needs at the center