A CVS pharmacy in Central Square, Cambridge. (Photo by Sarah Betancourt)

ON JUNE 11, the Massachusetts Health Policy Commission will release its final review of the proposed affiliation between CVS Health and Mass General Brigham. The arrangement would allow approximately 80 nurse practitioners at 37 CVS MinuteClinic locations across the state to join MGB’s contracting network and accountable care organization as affiliated primary care clinicians.

The Health Policy Commission conducts these data-driven reviews to assess how proposed provider affiliations may affect health care costs, the Commonwealth’s ability to meet its cost-growth benchmark, market competition, quality of care, and consumer access and equity.

The CVS-Mass General Brigham proposal sits at the intersection of two of the state’s most pressing health care challenges: a worsening shortage of primary care providers and an affordability crisis that strains families, employers, and public programs.

We think the proposal merits approval as a worthy experiment – but only if state officials make sure that it’s structured to deal effectively with both of those challenges.

The preliminary review released by the commission in April projected that the affiliation could add more than $40 million annually to commercial health care spending in Massachusetts by the third year of implementation. CVS and Mass General Brigham dispute that estimate, arguing that the true increase would be closer to $13 million to $22 million annually.

While parties disagree about the exact number, the larger policy question remains the same: How can Massachusetts expand access to primary care without further accelerating unnecessary health care costs?

On the access side, CVS and Mass General Brigham – the state’s largest health care provider network—try to make a forceful case, arguing that with an estimated 750,000 Massachusetts adults lacking a usual source of primary care, their proposal aims to mitigate the primary care shortage that forces many people across the state to face long waiting lists, and, increasingly, even to rely on artificial intelligence to fill gaps in care.

The plan calls for primary care at CVS MinuteClinics to include a broader slate of adult services, including comprehensive physicals, preventive care, and chronic disease management—building on the more limited set of services they have historically provided on an episodic basis (e.g., strep throat tests, vaccinations, or minor injury care) that constitute what the Health Policy Commission calls “convenience care.”

CVS-Mass General Brigham project that approximately 34,000 patients could be receiving primary care with a MinuteClinic nurse practitioner within three years, with the clinics ultimately serving as many 120,000 adults. That would begin to make a meaningful contribution toward addressing the state’s primary care shortage.

Yet the proposal raises questions about who will benefit from that expanded access. CVS has implemented similar primary care models in several other states, largely serving commercially insured patients. Massachusetts appears likely to follow that pattern. Today, 81 percent of MinuteClinic visits in Massachusetts are covered by commercial insurance.

Notably, CVS has indicated that it does not plan to participate immediately as a primary care provider in the state’s Medicaid program — MassHealth. While MassHealth patients would retain access to MinuteClinics for episodic convenience care, CVS will not yet commit to becoming a significant source of ongoing primary care for MassHealth members and participate in the population-based payment model that over 75 percent of other primary care practices in the state have participated in since 2023. Whether that changes in the future remains uncertain.

The proposal would also essentially end the offering of pediatric services currently available at Massachusetts MinuteClinics. Unlike in other states, where CVS has maintained convenience care for children while expanding adult primary care, the current Massachusetts plan would eliminate pediatric visits other than vaccinations for children over age 5. CVS and Mass General Brigham attribute this decision to state regulations, although their interpretation will face scrutiny from regulators.

Affordability concerns are equally significant.

The Health Policy Commission found that commercial reimbursement for nurse practitioner visits at Minute Clinics would increase by an average of 129 percent if the affiliation proceeds and CVS joins MGB’s expensive insurance contracts. Under their current proposal, CVS would bill those higher rates for visits by commercially insured patients regardless of whether visits are for primary care or convenience care.

Mass General Brigham, meanwhile, would benefit from additional referrals for laboratory testing, imaging, specialty consultations, and hospital-based services.

The parties dispute the Health Policy Commission’s methodology for estimating how much new utilization and referral revenue would result. They argue that MinuteClinic patients may be healthier than typical new primary care patients, and correctly note that individuals lacking primary care often require additional services when they first establish a longitudinal relationship with a primary care clinician.

We agree. More utilization is not a problem if it reflects appropriate and needed care.

But even under the parties’ own analysis, $10 million in additional spending would result from higher prices rather than increased utilization. Those higher prices stem largely from Mass General Brigham’s pricey reimbursement rates, among the highest in the Massachusetts market.

This reality points toward potential compromise.

At Thursday’s meeting, the Health Policy Commission will likely refer the matter to the attorney general and raise concerns with the Department of Public Health, even if it revises its spending estimates downward.

The attorney general will need to examine whether, with the additional cost burden coming at a time of such great health care affordability challenges, consumer protection laws may be violated. The Department of Public Health, which has to license the CVS sites, could question whether the high pricing and referral scheme evidence any “lack of responsibility or suitability” to operate a full-service clinic, as CVS is now proposing.

It would be a stretch for either the attorney general or the Department of Public Health to win a legal challenge if they sought to block the transaction outright.

But CVS and Mass General Brigham should feel some sense of concern and responsibility for a proposal that is projected to add additional health care spending burdens in our state. So, rather than litigating whether the affiliation should occur, policymakers should focus on the conditions under which it could proceed.

First, CVS should not receive reimbursement rates approaching those negotiated by Mass General Brigham for services at its facilities. Some may be appropriate, but payment levels should remain closer to market averages.

Any future increases should be tied to real steps to serve MassHealth members and expand access beyond commercially insured populations. An alternative would be to reimburse primary care services through a planned per member, per month payment, plus the potential to earn bonuses for good quality and for keeping the total cost of care in check—a payment approach currently being discussed by the state’s Primary Care Access, Delivery, and Payment Task Force.

Second, regulators should establish a Mass General Brigham revenue growth target tied to patients receiving primary care through this affiliation. Using the Massachusetts All-Payer Claims Database, regulators can track whether Mass General Brigham realizes referral revenue beyond agreed-upon thresholds. If revenue exceeds those updated annual targets, Mass General Brigham should return the excess through payments to the Connector Care Trust Fund or the Health Care Safety Net. Such an arrangement could sunset after five or six years.

We hope the Health Policy Commission board uses its June 11 meeting to recommend a path toward a compromise that would allow this proposal to proceed, while protecting consumers from unnecessary spending increases. In the end, however, achieving that outcome will depend on whether the attorney general’s office or the Department of Public Health is willing to push CVS and Mass General Brigham to accept meaningful conditions.

Massachusetts should not have to choose between expanding primary care and protecting affordability. The CVS-Mass General Brigham affiliation can advance both goals—but only if regulators ensure that the benefits of more access are not overwhelmed by higher prices.

Paul Hattis is a senior fellow at the Lown Institute. John McDonough is a professor at the Harvard TH Chan School of Public Health. They co-host the monthly “Health or Consequences” episodes of The Codcast.