Working toward a Fall 2009 start date, the pace of activity with CMS has intensified, including weekly calls to clarify or resolve the remaining demonstration issues. Although most of the big issues have been resolved, the remaining ones, which are technical in nature, have the potential for adding significant complexity to the demonstration. One of the thorniest issues is the identification of demonstration physicians. While it is now clear that only primary care physicians can be participating physicians, one complication has resulted from the different ways CMS and Community Care look at participating providers. Unlike Community Care, which is built around the practice, CMS is looking at the individual physician. This is making the crosswalk more complicated and will make capturing comparative data more difficult. A second, related challenge, is defining the type of agreement NCCCN needs to have in place with participating physicians and/or practices.

While CMS has made every effort to fit the demonstration within the Community Care system and structure, design variations can bring significant complications. Community Care staff members expect to receive a substantially completed Demonstration Protocol from CMS by mid-August.