This evening, CMS announced the next generation of BPCI. Open enrollment for the new payment model, BPCI Advanced, begins Thursday, January 11, 2018. Here's our early perspective on the new program.
In this evening's press release, CMS shared some of the program’s characteristics:
- Voluntary model, which qualifies as an Advanced APM under MACRA
- A single retrospective bundled payment and one risk track, with a 90-day Clinical Episode duration
- 29 inpatient bundles anchored by 105 MS-DRGs
- 3 new outpatient bundles identified by 30 HCPCS codes
- Bundles include hip/knee replacement, CABG, AMI, PCI, Cardiac defibrillator, and back and neck procedures except spinal fusion
- Payment is tied to performance on quality measures
- Preliminary Target Prices are provided in advance of the performance period
- CMS will only release data to those who submit non-binding applications.
- The enrollment period will be open for 2 months, ending on March 12th.
- The program will start on 10/1/18 and will run for 5 years
- There will be one other start date option on 1/1/20
From our perspective, BPCI Advanced aligns with many of our expectations, but also has elements which we are still vetting. Here is our preliminary take:
- What we’re encouraged by: The addition of OP bundles; A PGP Episode Initiator option with an updated PGP pricing model; CMS will now provide 20% stop loss at the Episode Initiator level.
- What we’re concerned about: Unlike the original BPCI program, BPCI Advanced does not appear to have an option for post-acute providers to be Episode Initiators; BPCI Advanced won’t qualify providers for the Advanced APMs payment track until MACRA Year 3, despite a performance period in 2018; BPCI Advanced will exclude beneficiaries aligned to Next Generation ACO or MSSP Track 3.
- What we’re still waiting for more detail on: Episode definitions; the target pricing methodology and baseline period; and how the Composite Quality Score (CQS) Adjustment Amount is calculated.
We’ve spent the evening reviewing a variety of materials and information CMS has provided, including:
- Participant eligibility for non-conveners and conveners
- Model timeline and roadmap
- Definition of clinical episodes
- List of quality measures
- Details on application process
- Application materials
There’s a lot to digest. Rest assured, we have helped all of our practice partners achieve success in BPCI and are ready to help you assess, and, if appropriate, enroll in BPCI-Advanced.
We will be sharing a lot more information on a webinar, “BPCI Advanced 101” on Friday, 1/12 at 3 pm EST. On the webinar, we’ll also give an overview of Archway Academy, an online learning platform dedicated to helping providers who are working with us to better understand and prepare for BPCI-Advanced.
Can’t attend? Contact us directly and we’ll provide a link to the recording.
We look forward to working with you soon.