Prescription drugs awaiting pick up at a CVS pharmacy in Massachusetts. (Phoyo by Sarah Betancourt) field_54b3f951675b3

HEALTH REGULATORS REITERATED their uncertainty about the scope of primary care services that Mass General Brigham and CVS MinuteClinic could deliver as they released a finalized report Thursday that advances the pending partnership while incorporating new stipulations on care delivery.

After initiating a rare probe in September of the clinical affiliation that’s poised to transform 37 MinuteClinic sites into primary care clinics, the Health Policy Commission board voted to release the final cost and market impact review. The movement came as the Senate released a primary care reform bill to pump significantly more money into the sector and expand the workforce.

Regulators have been intrigued about the prospect of an innovative care model to expand primary care access, but the sticker shock continues to linger and the HPC said Thursday it “remains uncertain” whether or when MinuteClinic will “provide comprehensive, high-quality primary care.” The affiliation comes with some limitations, such as MinuteClinic not providing oral health screenings, prescribing controlled substances and offering telehealth visits initially.

The arrangement is expected to deliver primary care to tens of thousands of adults and scale back MinuteClinic’s existing menu of “convenience care” offerings like flu shots and vaccines. Pediatric primary care is not included in the model.

The HPC initially estimated the affiliation would raise commercial healthcare spending by $40.2 million.

CVS and MGB argued the HPC’s analysis made a “fundamental statistical error” and that the cost impact should be between $13.8 million to $22.3 million. In their response, the parties said Massachusetts is facing a “deepening primary care shortage.”

“While this approach may not satisfy every view of what primary care expansion ought to entail, continued inaction risks exacerbating access challenges that the existing delivery system has thus far been unable to solve,” CVS and MGB said.

The HPC on Thursday trimmed its cost impact estimate to $39.9 million, with the figure still largely stemming from CVS patients receiving primary care at significantly higher MGB prices. The transaction cannot be finalized for 30 days, according to the HPC.

The final report is being shipped to the Department of Public Health, where the affiliation is not subject to a Determination of Need request but will need clinic licensure approvals, an HPC spokesperson said. The report is also headed to Attorney General Andrea Campbell’s office, which has separate authority to monitor the healthcare market, the HPC said.

MinuteClinic also agreed to new conditions and reporting requirements with the HPC. That includes the parties exploring ways to mitigate costs like incrementally phasing in MinuteClinic advanced practice providers into MGB’s contracted rate schedule over two years.

“Primary care faces increasing challenges in Massachusetts, and our residents continue to face mounting pressure related to health care affordability and access,” HPC Executive Director David Seltz said. “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.”

As it gradually transforms its locations and seeks full clinic licensure from DPH to deliver primary care, MinuteClinic pledged to prioritize sites that have the “greatest unmet need” based on the HPC’s assessment. MinuteClinic also plans to develop and implement an outreach plan for MassHealth patients and “other underserved populations,” the HPC said.

MinuteClinic previously planned to discontinue convenience care for children, but it now intends to keep the service. The DPH confirmed that MinuteClinic can receive full clinic licensure to provide convenience care to both adults and children, the HPC said.

As the HPC monitors the primary care rollout, the agency attached new reporting requirements around the number of MinuteClinic advanced practice providers and other clinicians who have joined MGB contracts, MinuteClinic prices and increases for commercial insurers, a list of sites that receive full clinic licensure each year, the patient payer mix, the annual volume of primary care and convenience care visits, and the annual volume of specialty referrals.

The HPC also wants to know MinuteClinic’s progress in joining MGB’s accountable care organization, and whether more services — particularly telehealth, oral health screenings, and full behavioral health screenings and medication management — have been added.

“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,” HPC Board Chair Deborah Devaux said.