Preliminary review of MGB-CVS proposal estimates $40 million in increased spending annually
BOSTON — Today, the Massachusetts Health Policy Commission (HPC) Board issued the preliminary report on the cost and market impact review (CMIR) of the proposed contracting affiliation between Mass General Brigham (MGB) and CVS MinuteClinic.
Under the proposed transaction, which was filed as a material change notice with the HPC in June 2025, CVS plans to transform 37 MinuteClinic locations throughout Massachusetts into MinuteClinic Primary Care (MCPC) and proposes to offer longitudinal primary care and continuing "convenience care" services for adults only at these sites co-located in CVS retail locations. As part of the transition, MCPC is proposing to join MGB’s Accountable Care Organization (ACO), participate in MGB’s payer contracts, and have access to MGB’s population health management infrastructure.
The parties expect that approximately 80 MCPC Advanced Practice Providers would begin managing panels of 1,500 patients each, creating capacity to serve 120,000 adult primary care patients statewide. As CVS expects MCPC to serve a smaller number of primary care patients in the first few years, the HPC’s cost and market impact projections are based on estimates of 42,000 patients.
The HPC’s preliminary CMIR report of this transaction found that MinuteClinic’s transition to primary care has the potential to increase access to adult primary care services, although CVS would need to prioritize transition timing and support for sites in areas of higher need and target its outreach efforts thoughtfully to meaningfully improve access for populations facing socioeconomic barriers to care. The shift away from all-ages convenience care, however, would reduce access to those services, particularly for children.
The HPC also found that the transaction is likely to result in an increase to commercial health care spending of approximately $40.2M annually by year three of the transaction, even if MCPC only serves 35% of its primary care capacity by that point, consistent with its expectations. This includes increased spending as new primary care patients join MCPC and adopt care patterns similar to existing patients of other MGB affiliates ($27.7 million) and higher prices for both MCPC’s continuing convenience care services ($6.6 million) and the convenience care services that would need to move to other providers ($5.9 million). These spending impacts could be substantially higher if more patients choose MCPC primary care providers.
“In the midst of a primary care access crisis in the state, the proposed affiliation between Mass General Brigham and CVS represents a potential for innovation in primary care delivery in Massachusetts, as well as the potential for increased access for residents. Alongside this, it could represent an additional $40 million in annual health care spending,” said Deborah Devaux, HPC Board Chair. “We appreciate the continued collaboration of the parties during this review and public accountability process, and look forward to their forthcoming responses to the questions raised by commissioners as we issue this preliminary report.”
“Primary care is the foundation of a strong, sustainable health system, yet it faces increasing pressures in Massachusetts,” said HPC Executive Director David Seltz. “We must balance this need for primary care alongside the existing affordability challenges our residents face. The HPC’s review of this proposed new model, conducted in the service of protecting Massachusetts consumers, will help ensure that this proposal meets those goals.”
Cost and Spending Projections
Utilizing CVS’ assumptions that the payer mix of the new primary care panel will reflect that of MinuteClinic’s current payer mix, which is 81% commercial, and that MCPC would fill 35% of its primary care panels by year three with “moderate acceptance” of its new primary care model, resulting in approximately 42,000 primary care patients by year three, the HPC has projected:
- This transaction is likely to increase commercial health care spending by approximately $40.2 million annually. This includes:
- Spending for New Primary Care Patients: CVS projects that patient panel sizes will reflect “moderate acceptance” of the MCPC model by year three, and that payer mix will remain the same as before the transaction. Applied to these projections, the increases in claims and non-claims spending would have an annual commercial spending impact of $27.7 million.
- Repricing for Walk-In Services: Combining this price differential with the parties’ stated expectations of the size of the primary care panel, the HPC estimates a likely annual commercial spending increase of $6.6 million.
- Diversion of Some Walk-In Patients to Other Providers: The HPC found that 66% of encounters would divert to primary care providers in physician offices; 18% would divert to urgent cares; 12% would divert to hospital outpatient departments; and 4% would divert to other settings. On average, comparator convenience care providers’ prices were 94% higher than MinuteClinic’s. Combining this price differential with the parties’ stated expectations of the size of the primary care panel, the HPC estimates an annual commercial spending increase of $5.9 million.
- As these are conservative estimates of spending impacts in year three based on the parties’ projections of “moderate acceptance” of their model, these annual spending impacts would increase if more primary care patients joined the MCPC patient panel, and they would be significantly higher if MCPC sites were to each fill their primary care patient panels to the maximum.
- There are further cost and market impacts that the HPC is unable to quantify in its analysis, including the impact of additional bargaining leverage for MGB as a result of this expansion of MGB’s primary care footprint, and thus a possible increase in its commercial prices.
- Increasing primary care capacity can result in longer term savings. Studies have found greater savings in the context of high-quality, long-term longitudinal care with the same provider. The potential for similar savings here is dependent on the long-term success of MCPC's model and the quality of care they would provide.
Market and Access Projections
- The HPC found the potential for improved access to primary care, particularly in communities that face greater barriers to care. This could result in decreased wait times for primary care, increased primary care clinicians in MGB’s network, and shifts in emergency department utilization.
- The shift away from all-ages convenience care would eliminate access to convenience care for children and reduce access for adults.
- The innovative model of providing primary care services in a retail setting in partnership with a large Massachusetts health system will require a substantial change from the current model. It is unclear whether, under the parties’ current plans, MCPC will ultimately provide comprehensive, high-quality primary care, particularly given that much will depend on how those plans are implemented.
Next Steps for Review
The CMIR is a comprehensive, data-driven review that assesses the impact of a proposed contracting affiliation on costs and the Commonwealth’s ability to meet the health care cost growth benchmark, market functioning, quality of care, and health equity and access for consumers. The HPC leverages confidential information provided by the transaction parties and other market participants, public data sources including those collected by the Center for Health Information and Analysis, and the advice of expert consultant teams in order to build its analyses.
Following this preliminary report, parties will have 30 days to respond to questions and concerns raised in this report, and potentially include commitments regarding mitigation of spending impacts, as well as commitments to maximize the potential for improved access to high-quality care. The HPC will review these responses and develop a final public report.
The HPC does not have the authority to prohibit a transaction or to require conditions of approval but may refer its report and findings to the Office of the Attorney General (AGO), Department of Public Health (DPH), or other state agencies for possible further action on behalf of consumers in the health care market. Through this process, the HPC also seeks to encourage providers to evaluate and take steps to minimize negative impacts and enhance positive outcomes of any proposed change.
The transaction may not be finalized until 30 days following the publication of the final CMIR report.
Read more about the preliminary CMIR and the HPC’s transactional review process.
A recording of the meeting and presentation materials are available on the HPC’s website.
