The New CMS Bundle Model: Understanding Key Decision Points for Program Participation

On January 9, 2018, CMS announced the Bundled Payment for Care Improvement Advanced (BPCI-A) initiative¹. This is the first new value-based payment model to be announced since President Trump took office, and its release appears to signal CMS' return to the agenda of shifting payments from volume to value. BPCI-A is a follow up to the original BPCI model, which launched in late 2013 and will conclude at the end of Q3 of this year, just before BPCI-A will begin enrolling patients. BPCI-A is planned to extend through the end of 2023.

The following timeline outlines the milestones en route to October 1, 2018, when the program will go live.

Timeline for BPCI Advanced Enrollment:

March 12, 2018: Application portal closes

May 2018: CMS distributes pricing data to applicants

June 2018: CMS distributes Participant Agreements to applicants

August 2018: Applicants submit bundled selection

October 1, 2018: Program goes live

As the March 12 sign-up deadline for BPCI-A approaches, acute care hospitals and physician groups — the 2 entities that will initiate episodes under the new model – must quickly assess whether they should participate, although they need not commit to participation until August. Here are some of the key questions healthcare organizations should ask when assessing the decision to take part in BPCI-A:

Why participate in Medicare’s new voluntary bundled payment program?

Successful participants in the current BPCI program have engaged physicians, improved care transitions, integrated with post-acute providers, and realized financial rewards. As evidenced by the continuation of the mandatory Comprehensive Care for Joint Replacement initiative, the announcement of BPCI-A, and the need to increase options for Advanced Alternative Payment Model (APM) participation, it is likely that Medicare will continue to expand bundled payment programs in the future. Moreover, adoption of commercial and mandatory Medicaid bundles is growing. Based on the presence of voluntary and mandated bundle models, providers need to be positioned for a future that will include both.

Does your organization have a strategic goal to prepare for value-based payment?

As the proportion of healthcare payments continue to shift to value from volume, it is a strategic imperative to gain the competencies required to succeed in the new order. BPCI-A can be a critical step to gaining the organizational capacity to deliver high-value episodic care. Key competencies for success include: the infrastructure to engage in targeted quality improvement and care redesign, the use of data to assess bundle pricing and program performance over time, the deployment of purpose-built technology for episodic care enabling patient identification, decision support, and data sharing between acute and post-acute providers; and the creation and maintenance of high performing post-acute and physician networks.

Are you looking to engage specialists and hospitalists in value-based arrangements and an alternative payment model?

Accountable Care Organizations, the most widely disseminated APM to date, have primarily focused on populations and ambulatory care. As a result, generalists and specialists with predominantly outpatient practices have been best suited to participation in the model. BPCI-A affords the opportunity for specialists with a significant hospital practice and hospitalists to participate in an APM. BPCI-A will qualify as an advanced APM, and in so doing, represents the first large scale chance for these clinicians to qualify for advanced APM participation, sparing them the reporting burden and potential penalties of the Merit-based Incentive Payment System (MIPS). Perhaps most notably, hospitalist and specialist involvement in BPCI-A and the acute episodes it represents is a needed counterpart to the focus of ACOs, which is chronic disease management and prevention.

What kind of resources do I need to commit to successfully participate?

For BPCI-A, hospitals and physician groups who choose to initiate episodes (‘initiators’) can “go it alone” or they can work with a convener. Conveners’ offerings vary widely, and may include providing up front capital to build program infrastructure, sharing risk and reward with initiators, and software, analytics, performance networks, and knowledge assets of specific care redesign approaches to enable program success. For organizations going it alone, substantial resources in each of these areas, as well as committed leadership, are needed. For those working with a convener, in addition to committed leadership, there will be a requirement for personnel to oversee the program and to educate and guide staff along the continuum of an episode to work in support of the program’s goals.

BPCI-A will require an investment in people and processes to support coordinated, high-value care as patients progress through an episode. This includes the use of decision support to help identify patients who may successfully recover at home, the existence of high performance networks, information technology enabling the flow of key information, and professionals who can manage critical elements of the initiative. For those willing to make the requisite investment, the new CMS bundle model represents an important opportunity to drive more spending into value-based arrangements.

Reference:

1. BPCI Advanced. CMS.gov. innovation.cms.gov/initiatives/bpci-advanced. Published January 9, 2018. Updated February 5, 2018. Accessed February 6, 2018.