The Centers for Medicare and Medicaid Services is moving ahead with a new voluntary bundled payment model despite a call from the American Hospital Association to delay the program’s application deadline from March 12 to April 16.
Among myriad requirements, the new version of the bundled payment program sets out minimum levels of use for certified electronic health records systems. EHRs will be crucial to success in the program because they’ll be essential in coordinating complex care cases, experts believe.
However, the starting date for application deadline was a bone of contention for the AHA, which wrote a letter to CMS asking the agency for a month-long delay in implementing the Bundled Payments for Care Improvement Advanced Model (BPCI Advanced)—in which participants must bear financial risk, implement care redesign activities and use certified electronic health records—and to provide a complete package of detailed programmatic information.
The association says it agrees with the principles of BPCI Advanced, which seeks to “transform care delivery through better aligned incentives for providers, as well as through performance and financial accountability.” However, its letter made the case that the CMS announcement about the model and release of educational materials “raise important questions for our members about the model’s implementation,” noting that “of particular concern is the lack of sufficient operational detail about the model, making it difficult for hospitals and clinicians to make well-informed decisions as to participation.”
Nonetheless, CMS contends that it has provided a plethora of information on its website about applying for and participating in the new voluntary bundled payment model, as well as hosted a couple of question-and-answer webinar sessions to further detail its plans.
At the same time, the agency points out that while participants must apply to the BPCI Advanced model by March 12, they do not need to commit to the program until August 1. The first cohort of participants in BPCI Advanced will start on October 1, and the model performance period will run through Dec. 31, 2023.
“Everyone wants more time if they can get it—no one likes a deadline,” says Chris Garcia, CEO of Remedy Partners, a risk-bearing convener in the BPCI Advanced program. However, Garcia notes that the government is moving quickly “to create a seamless transition from the original BPCI program,” which ends on September 30.
It’s “not the end of the world” if clinicians don’t meet the March 12 application deadline for the first cohort of participants in BPCI Advanced, according to Garcia, who points out that CMS will provide a second application opportunity in January 2020.
Garcia’s Remedy Partners is a BPCI Advanced convener, an organization that brings together multiple independent parties—such as hospitals and physicians—that are involved in delivering care across an episode, and is responsible for distributing the bonus from, or paying the penalty to, the payer.
BPCI Advanced, which qualifies as an Advanced Alternative Payment Model (Advanced APM) under the agency’s Quality Payment Program for clinicians, will test a new iteration of bundled payments for 32 different clinical episodes, such as major joint replacement of the lower extremity (inpatient) and percutaneous coronary intervention (inpatient or outpatient).
“The previous bundled payment program was 48 different bundle definitions, so this one is actually less with only 32,” observes Garcia. Of those 32, BPCI Advanced will initially include 29 inpatient clinical episodes and three outpatient clinical episodes. However, CMS may elect to revise the clinical episodes in on an annual basis beginning Jan. 1, 2020, which will apply to both new participants and existing participants.
According to CMS, participants must use certified EHR technology (CEHRT) to document and communicate clinical care to their patients or other healthcare providers. For hospitals that are non-convener participants, the hospital must use CEHRT. For Physician Group Practices or PGPs that are non-convener participants, at least 50 percent of the PGPs eligible clinicians must use CEHRT. For those convener participants that will have hospital and PGPs as episode initiators, the hospitals must use CEHRT and at least 50 percent of the eligible clinicians in each PGP must use CEHRT.
Health IT is “the beginning, middle and end of success in bundled payments,” concludes Garcia, adding that “you can’t really administer a program at scale without it.”
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