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SD 3894

Primary Care Task Force Statutory Deliverable #2: Data and Reporting Requirements for Primary Care Payments

194th Legislature (2025-2026)

Payers must attest and be audited to ensure 90–95% of advanced primary care payments flow to primary care practices, with transparent MA-RPO reporting.

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Bill Summary · SD 3894

Overview

SD 3894 (Massachusetts, 194th Session) addresses data, reporting, and transparency requirements related to primary care payments as part of the Massachusetts Primary Care Access, Delivery, and Payment Task Force (PCTF) framework. It builds on Deliverable #2 and ties into Deliverable #4 and Deliverable #3 by strengthening accountability and ensuring funds flow to primary care practices.

Main purpose and intent

  • Enhance transparency around how primary care payments flow within health systems.
  • Ensure that investments in primary care are actually directed to primary care practices or directly support them.
  • Provide attestation, audit, and reporting mechanisms to monitor compliance with primary care spending targets and related affordability goals.

Key provisions and changes

  • Attestation and Audit requirements

    • Primary care practices and provider organizations participating in advanced primary care payment models must attest that payments are paid to or directed to primary care practices in line with MassHealth's Sub-Capitation program.
    • Attestation data would be subject to payer audits to verify that 90–95% of payments support primary care practices.
    • Providers participating in the advanced model would be accountable for enhanced practice capabilities and improved patient outcomes.

  • Reporting through the MA-RPO Program

    • CHIA and the Massachusetts Health Policy Commission (HPC) would collect information on the flow of primary care payments within provider organizations as part of the MA Registration of Provider Organization (MA-RPO) program.
    • Data to be gathered would include both claims and non-claims revenue, and how funds flow to primary care within hospital-based organizations.
    • The MA-RPO reporting requirements would be developed with input from provider organizations, payers, MassHealth, and other stakeholders; focus on minimizing administrative burden.

  • Separate primary care contracts and potential separate TINs

    • Encourage development of separate primary care contracts within large health systems to clarify terms and ensure payments support primary care practices.
    • Promote consideration of separate Tax Identification Numbers (TINs) for primary care business units to facilitate transparent distribution and accounting.
    • Contracts and TIN separation should align with MassHealth Sub-Cap Program processes and not increase overall health expenditure or premiums.

  • Alignment with Deliverable #4 and cost-control

    • Reporting and attestation mechanisms are intended to support policies ensuring primary care payments benefit primary care practices and do not simply flow to system-level administration or infrastructure.
    • Aim to improve accountability while avoiding added administrative burdens.

Who would be affected

  • Payers (insurance plans, MassHealth) and their contracts with provider organizations.
  • Primary care practices and provider organizations, especially those within large hospital-based systems or ACOs.
  • MassHealth and its sub-capitation and advanced primary care models.
  • CHIA and HPC, via MA-RPO data collection and reporting duties.

Procedural and timeline notes

  • The bill references ongoing PCTF deliberations, including discussions from meetings in 2025, and aligns with Deliverables #2 and #4.
  • It envisions future annual or ongoing reporting through CHIA and HPC, integrated with MA-RPO.
  • Action history indicates the bill was placed on file as of May 7, 2026, suggesting placement for further consideration or committee action.

Impact considerations

  • Potential increased transparency around funds flow and primary care funding.
  • Improved enforcement of primary care spending targets with measurable attestations and audits.
  • Possible administrative burden reduction through streamlined reporting and separate contracts/TINs, balanced against the need for robust data collection.

Compiled from official sources — confirm details with the bill’s official record.

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