HPC Finds Potential for Increased Primary Care Access; Projects Spending Impact of the Transaction to be $39.9 Million
BOSTON — Today, the Massachusetts Health Policy Commission (HPC) Board issued the final cost and market impact review (CMIR) report on the proposed contracting affiliation between Mass General Brigham (MGB) and CVS MinuteClinic. The HPC submitted the report to the Massachusetts Department of Public Health (DPH) and MassHealth for consideration in connection with clinic licensure and other regulatory determinations, and to the Office of the Attorney General (AGO) for consideration in the context of the AGO’s authority to monitor the health care market.
Under the proposed transaction, CVS plans to transform 37 MinuteClinic locations throughout Massachusetts into MinuteClinic Primary Care (MCPC) clinics offering longitudinal primary care for adults and continuing "convenience care" services for all ages 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 gain access to MGB’s population health management infrastructure.
The HPC’s preliminary report published in April found that MinuteClinic’s transition to primary care has the potential to connect up to 120,000 Massachusetts residents to a primary care provider through a novel care delivery model, and is likely to result in a substantial increase to commercial health care spending.
The final report updates the preliminary findings to incorporate commitments secured by the HPC from the parties and responds the parties’ joint response to the preliminary report. These include:
- Noting that the parties acknowledge that a substantial portion of the likely spending impacts are due to MGB’s uniquely high rates and commit to exploring ways to mitigate these impacts.
- Updating the spending impact for convenience care diversions from $5.9 million to $5.5 million to account for the possibility that some convenience care could be provided as part of the new MCPC primary care relationship and thus would not need to be diverted. This decreased the total projected impact from $40.2 million to $39.9 million annually once the MCPC sites are operational and the new MGB rates are in effect, assuming that MCPC fills its primary care panels to 35%, based on the parties’ own expectation of “moderate acceptance” of their model by year three.
- Emphasizing that the HPC’s projected $39.9 million annual spending impact is conservative; if MCPC were to fill its primary care panels to 100%, the annual spending impact would likely be $91.5 million.
- Highlighting the potential of the parties’ new commitments, such as to maintain pediatric convenience care and to provide targeted outreach to MassHealth patients, to mitigate the HPC’s concerns about equitable access highlighted in the Preliminary Report, as long as the parties prioritize meaningful, measurable action on these commitments.
- Added further discussion of the limits of the MCPC model compared with comprehensive primary care standards, including assessment of the implications of the proposed plan not to prescribe controlled substances.
The parties’ response does not materially change the HPC’s conclusions regarding the scope of likely spending impacts. The HPC welcomes the parties’ new commitments to help maximize the benefits of the transaction and minimize some of the identified concerns, including the commitments to explore ways to mitigate the identified spending impacts, to maintain pediatric convenience care, and to provide targeted outreach to MassHealth patients. If the parties prioritize meaningful, measurable action on these commitments, concerns about affordability and equitable access may be mitigated.
Because the parties propose a novel model for providing primary care in the state, it will be important for the Commonwealth to monitor the implementation of this new model, progress on the parties’ stated commitments, and the impacts on health care costs, quality, and equitable access over time. Accordingly, the HPC is requiring certain reporting from the parties to allow for ongoing monitoring of these impacts.
“This transaction represents a potential for innovation in primary care delivery in Massachusetts, as well as the potential for increased access for residents. We appreciate the collaboration of the parties during this review and public accountability process -- as well as their pledge of continued partnership with the HPC,” said Deborah Devaux, HPC Board Chair. “This substantial review was conducted in the service of protecting Massachusetts consumers, and CVS’s and MGB’s related reporting and commitments align us in the shared goal of more accessible, equitable, and affordable health care for all residents.”
“Primary care faces increasing challenges in Massachusetts, and our residents continue to face mounting pressure related to health care affordability and access. As we seek to test out innovative solutions, we must continue to balance the need for primary care with the need to improve affordability of this care,” said HPC Executive Director David Seltz. “The HPC appreciates CVS and MGB’s commitment to exploring ways to mitigate the spending impacts identified by this independent, data-driven review. The HPC will monitor progress on these commitments and the long-term impacts of this affiliation on the health care market.”
The transaction may not be finalized until 30 days following today’s publication of the final CMIR report. The full findings from the CMIR and more information on the HPC’s transactional review process are available online.
A recording of the Board meeting and presentation materials are available on the HPC’s website.
