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Keeping Up With CMS: Timeline Guides for New and Evolving Alternative Payment Models

Sg2, a Vizient company
07/30/19

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Tawnya Bosko, DHA, Principal

There’s a lot happening in traditional Medicare alternative payment model (APM) development and evolution. Because we recently passed the Bundled Payments for Care Improvement Advanced (BPCI Advanced) application deadline on June 24 and the Medicare Shared Savings Program (MSSP) notice of intent to apply (NOIA) deadline on June 28, I want to remind organizations of the various programs and their associated deadlines, as well as the opportunity (or lack thereof) for entry. Let’s take a look at …

Medicare Shared Savings Program Pathways to Success

The long-awaited revisions to the MSSP through Pathways to Success are officially effective with July’s new cohort. The NOIA for a Jan. 1, 2020 start was due June 28, with application window times shown below (keep in mind that the deadlines are at noon ET for this program).

Don’t despair if you missed the NOIA deadline; unlike BPCI Advanced, there will be additional opportunities to enter the MSSP accountable care organization (ACO) model with the NOIA beginning in May to June of 2020 for entry in January 2021. It’s typical in this program to follow a similar annual cadence.

Direct Contracting

CMS’ new model, Direct Contracting, was designed with features of Next Generation ACO (which is no longer accepting new applicants) and Medicare Advantage. Full details are yet to be released, but like the MSSP, you must submit a letter of intent by early August.

Even if you are unsure about participation in this program, you should submit the letter of intent to preserve your option to apply. 

Bundled Payments for Care Improvement Advanced

The bad news for those who haven’t applied to BPCI Advanced: the last window to enter the program closed on June 24. However, mandatory episodic models are expected to be released soon (more on that next). For those in the program or those who applied to the program to begin Jan. 1, 2020, some important dates are found below.

More bundled payment models imminent

CMS has announced new mandatory models through the Center for Medicare and Medicaid Innovation. Will there be more coming, potentially voluntary? Be prepared for the new Radiation Oncology (RO) episodic and End-Stage Renal Disease Treatment Choices incentive (ETC) models. These are still in proposed rule status — with comment period open for 60 days — but it’s important to pay attention to whether or not your organization or affiliates are included. RO is expected to start Jan. 1, 2020, or April 1, 2020, while ETC is planned for Jan. 1, 2020. Each will follow a different process for mandatory selection.

Emergency Triage, Treat and Transport

This model was announced fairly quietly, and if it gains traction, it could have a profound impact in the communities where it’s implemented. Until now, 911 services have only been paid by Medicare to transport patients to the ED. Emergency triage, treat and transport seeks to reduce unnecessary ED visits and associated costs by partnering with 911 services and their community. Components of the program include triage, treat in place (via on-site or virtual health) and transport to local clinics or urgent care sites. The request for applications has already been released, and the portal to submit applications will open later this summer. Keep in mind that this is a multipayer model. 

Primary Care First

Built on the framework of its predecessor programs, Comprehensive Primary Care (CPC) and CPC+ (which is no longer accepting applications), Primary Care First (PCF) is a multipayer medical home model targeted at primary care practices. Historically it hasn’t been available nationwide, but with the rollout of PCF, it will be expanding to additional states and regions. The request for applications for a January 2020 start is expected anytime. Historically, CMS has allowed simultaneous participation in CPC+ and MSSP ACOs, though there are crossover implications. More details on crossover with PCF and other APMs should be forthcoming.

 Next steps

As shown, there are many active, new and evolving Medicare payment models, and as health systems begin to transition to value-based care, it will be necessary to develop a defined strategy for alternative payment model participation—not to mention coordinate with payers and strategically align with physicians. Sg2 is well-positioned to not only help your organization evaluate your eligibility and readiness for alternative payment model participation, but also evaluate your preparedness for success in a value-based environment.

To speak to an Sg2 expert about how these new alternative payment models may impact your strategy, contact Sg2 today.

About the author. Drawing upon 20 years of experience in health care management and strategy, Bosko collaborates with health systems and payers to develop innovative and detailed plans for future growth. She has advised clients on strategies for mergers and acquisitions and the development of clinically integrated networks, strategies for provider-owned health plans, and overall strategies to enable organizations to transition to value-based payment and evolving delivery system structures. Sg2’s analytics-based health care expertise helps hospitals and health systems integrate, prioritize and drive growth and performance across the continuum of care.

Editor’s note: Kristin Oberfeld, associate principal, Sg2 consulting, contributed to this post.

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