For health systems and physician group practices across the country deciding whether or not to proceed in the Bundled Payments for Care Improvement (BPCI) Advanced program on October 1, there are various moving parts ahead. At this point, they’ve been digging through data, conditions and baseline numbers attempting to make heads or tails out of it all. And for those deciding to move forward, administrative tasks and thought-provoking internal conversations await.
Amid all this, the Centers for Medicare & Medicaid Services (CMS) announced recent updates to the program, as well as a "marginal" error that affected Preliminary Target Prices for some applicants’ episodes.
As organizations vet the decision to press forward, it is critical to consider entering the program sooner than later. Let’s break it down.
Minor Extension: CMS Participation Agreement
CMS granted access to the BPCI Advanced Participant Portal for those organizations that submitted applications by the March 12, 2018 deadline and were granted approval to move along in the process. *Note: this is different than data portal.
CMS also pushed the original deadline for the Participation Agreement up to August 22, 2018. However, the Participant Profile remains due August 8, 2018. This shift in the Participant Agreement deadline allows applicants more time to review updated sections within the agreement pertaining to the updated retroactive withdraw policy in March 2019. Additionally, CMS extended the deadline for three other required deliverables by 10 days to September 14, 2018. All of these deliverables must be submitted via the Participant Portal for each Bundled Payment ID.
While CMS has distributed the Participation Agreement via the BPCI Advanced Participant Portal, organizations have NOT been selected to participate. CMS also posted a Notice of Waivers of Certain Fraud and Abuse Laws in Connection with the BPCI Advanced Model in the Participant Portal. The CMS Payment Policy Waivers are outlined in Appendix E: 3-Day SNF Rule, Appendix F: Post Discharge Home Visit, and Appendix G: Telehealth of the BPCI Advanced Participation Agreement.
New “No-Risk” Offer: What Does It Mean?
CMS reiterated that they will retain the October 1 start date to both accommodate this update in Preliminary Target Prices and to recognize some applicants' requests for a later start date. CMS will now be allowing a one-time opportunity for all participants to retroactively withdraw Episode Initiators (EIs) and/or Clinical Episodes in March 2019. CMS also clarified that participants that retroactively withdraw EIs and/or Clinical Episodes will not be held accountable (e.g., no risk) for withdrawn episodes triggered during Model Years 1 & 2 (e.g., any episodes initiated on or after October 1).
Note that if a convener keeps at least one Episode Initiator OR a non-convener keeps at least one Clinical Episode but withdraws from all other Episode Initiators/Clinical Episodes on March 1, 2019, they will still be able to participate in BPCI Advanced in 2020.
While this extra five-month period is definitely a welcomed announcement by many potential participants, it should be cautioned that the performance data/insights gleaned during this time period will not be substantial. However, this essentially allows participants to elect any (or all) clinical conditions to buy more time to prepare their teams, further review baseline data and qualitatively monitor progress in their bundles of interest. This is a significant advantage to potential participants in BPCI Advanced.
Coupled with this announcement, CMS notified BPCI Advanced applicants of a marginal error that affected Preliminary Target Prices for some applicants and certain episodes. CMS has uploaded new data files with these minor adjustments.
BPCI Advanced Model: Timeline Review
Faced with the time challenges of sifting through the administration aspects of the program along with the arduous task of determining both volume and opportunity qualifications for each hospital, practice and condition, many organizations are feverishly attempting to make the best possible recommendation in which to move forward.
Review the timeline here.
Although this program runs for five years through December 31, 2023, CMS will allow for changes – additions / drops – for program participation starting on January 1, 2020. So, the evaluation and assessment being completed now is crucial to overall success in the program.
Early Entry: Could Mean Early Wins
As the BPCI Advanced program continues to evolve, every participant will be striving to lower costs while maintaining a high quality of care for the beneficiary. Simultaneously, it will increasingly become more difficult to achieve better outcomes year over year in the program due to the competitive landscape.
While the reality is that participating in BPCI Advanced is too soon for some organizations, the open application period in January 2020 is not too far off, so preparation is still highly valuable over the next 12 months.
By submitting an executed Participation Agreement and the other required deliverables, BPCI Advanced applicants will be well positioned to enter the program early and maximize success in achieving quality goals and savings targets.
To learn more about the capabilities needed to succeed in BPCI Advanced, please contact firstname.lastname@example.org and download our white paper: Ready, Risk, Reward: Keys to Success in Bundled Payments.