CMS’ Latest Innovation Model – The Making Care Primary (MCP) Model Includes Focus on Social Determinants of Health

On June 8, 2023, the Centers for Medicare and Medicaid Services (CMS) announced a new voluntary primary care model, the Making Care Primary (MCP) Model. Highlights include the following:

CMS will release a Request for Application and additional guidance later in the summer of 2023, with plans to accept applications by the end of summer 2024.

Three-Track Model

The MCP Model is a three-track model. Each track progressively varies based on value-based care expertise and offers considerable flexibility for providers that are new or transitioning to value-based care. 

Payor Engagement

Building on its payor engagement experiences under primary care innovation models (e.g., Primary Care First (PCF) and Comprehensive Primary Care Plus (CPC+)), CMS is working with state Medicaid agencies in the eight participating states, and will later engage with private payors, to expand the impact of the MCP Model’s primary care transformation goals.

Eligible Participants

Eligible participants are limited to organizations that are enrolled in Medicare, have at least 125 attributed Medicare beneficiaries, and have a majority (at least 51%) of primary care sites located in an MCP Model-eligible state. Participants in many other shared savings programs, like the PCF, Affordable Care Organizations (ACO) Reach and the MSSP, as well as Rural Health Clinics, Grandfathered Tribal Federally Qualified Health Centers (FQHC) and concierge practices are excluded from the MCP Model; however, at this time other FQHCs are not excluded. 

Notably participants in the MSSP can concurrently participate in the MCP Model during the first six months of its term only. No similar transition period is available for ACO Reach participants or other excluded participants.


The more than 10-year length of the support provided in the MCP Model provides an important opportunity for primary care providers, as they begin or continue their efforts to adapt to the evolving need to address social determinants of health, as well as the shift to value based payment models. Providers initially will need to confirm that they are not excluded based on their participation in the MSSP or other innovation models, and, if accepted in the MCP Model, should plan to terminate such conflicting participation.

© 2024 Foley & Lardner LLP
National Law Review, Volumess XIII, Number 174