On Jan. 9, 2018, CMS released the long-awaited and much-anticipated Bundled Payments for Care Improvement Advanced (BPCI Advanced) initiative. The announcement affirmed the agency’s commitment to alternative payment models (APM) as an integral component of its quest to find innovative and effective ways to manage health care costs.
“CMS’ intent is to realize enhanced care redesign that will result in greater care coordination, lower costs for Medicare beneficiaries, improved patient experiences and create higher quality outcomes. Key to this effort is offering providers incentives for participation,” said Jim Reilly, managing principal, at Vizient.
Of significance is that BPCI Advanced will qualify as an advanced APM and is a voluntary retrospective bundled payment program. It includes 32 clinical episodes; 29 within inpatient settings and three in outpatient settings.
Preliminary target prices will be set prospectively and will be made available before participants are required to select Clinical Episodes and finalize the Participation Agreement with CMS in August. Target prices for BPCI Advanced will be set semi-annually before the first performance period of each model year.
Reilly offered six tips for providers to consider as they evaluate whether the BPCI Advanced opportunity is right for them.
- Take advantage of a unique opportunity to obtain performance data. The application for BPCI Advanced is non-binding and, upon submission, you will get three years of Medicare claims data that will show your historical spend and utilization patterns. The data gives you the opportunity to see how your facility has managed care over a 90-day continuum, which is the time frame of a clinical episode in BPCI Advanced. You can use this data to understand performance gaps and engage physicians on how to better manage the overall total cost of care for Medicare beneficiaries. Remember, you don’t have to move forward with the program if you feel your organization is not ready. But apply, get the data. The application portal closes Monday, March 12, 2018 at 11:59 p.m. EST.
- Develop an exploration committee now. If you’re considering BPCI Advanced participation, develop a committee now to address and respond to the application and data request attestation. Committee representation should include professionals with experience in quality assurance, care redesign, organizational planning, risk, financial partnerships, and funds flow within a retrospective payment model.
- Apply in both participant categories. You may apply as a Convener, defined as a participant that brings downstream Episode Initiators together and shares financial risk with them, and/or as a Non-Convener. A Non-Convener bears only its financial risk and may be a physician group practice or acute care hospital. Because of the aggressive timeline, the application process may favor third-party firms that serve as Conveners. Such firms complete paperwork and manage data on an applicant’s behalf, but there are drawbacks. You should apply as a Non-Convener even if you’re going with a Convener. That will give you direct access to the data, and provide you the option to participate in the program on your own and not work with a Convener. And remember, the application is non-binding!
- Take advantage of the waivers. Under BPCI Advanced, CMS has expanded the number and types of partners with which hospitals may align financially. This is possible through waivers that promote coordination and alignment among other hospitals, physicians, institutional post-acute care providers and accountable care organizations.
- MACRA-participating physicians may be eligible for Qualifying Practitioner status. On the quality front, CMS has linked some quality metrics to the program’s economic terms. In BPCI Advanced, physicians will be more accountable for care, which can benefit them in ways not previously available. There is an opportunity to be eligible for Quality Participant status under the Medicare Access and CHIP Reauthorization Act (MACRA). By participating in BPCI Advanced, physicians may be able avoid the MIPS payment schedule and qualify for a 5 percent increase on their professional reimbursements. Physicians can qualify for this even if the hospital is the holder of the agreement with CMS, so participation could be seen as the hospital providing a significant benefit to its medical staff.
- Gain experience for the future. Voluntarily participating in BPCI Advanced now can give you invaluable experience that you can use in other types of risk contracting, such as a Medicare shared savings program arrangement, and down the road, capitation. In addition, there may be a future strategic opportunity to approach commercial payers and employers directly with the same type of risk product, thereby potentially increasing commercial market share. In other words, “We do this with Medicare, so why not apply it to a commercial population, as well?”
BPCI Advanced begins Oct. 1, 2018, and ends Dec. 31, 2023. The next enrollment period will be January 2020.
“This is my eighth CMS bundled payment program, so I’m dating myself here,” Reilly said jokingly. “But in all honesty, Vizient has written literally dozens upon dozens of these applications for members. We know what CMS is looking for and can respond to it. Data analytics are critical. Our technology can organize, link and benchmark all of the key metrics from members’ Medicare claims data to make informed recommendations.”
For more information about how Vizient and our team of experts can guide your organization through the new bundled payment program, click here.