The Centers for Medicare & Medicaid Services (CMS) announced yesterday that the application window for Cohort 2 of BPCI Advanced (Model Year 3) is open. The window runs through June 24, 2019, and is currently the last planned open window for applications for the voluntary program.
With this announcement comes a lot of information to digest. To help you navigate the program, we’ve pulled together our early takeaways: what we know, what we’re waiting for, and other points of interest.
What We Know Now
Let’s start with the timeline.
The application period opened on April 24, 2019, and will close June 24, 2019, at midnight EST.
CMS does not plan to have any more application periods, meaning this is the last chance for providers to join the program.
Just as with Cohort 1, the application and enrollment timeline will be tight but manageable. CMS says it will send historical baseline data in “late September,” and that participants must make a decision in November.
CMS has rolled forward the four-year historical baseline period for Model Year 3 to October 1, 2014 through September 30, 2018. The historical baseline period for Cohort 1, which covered Model Years 1 and 2, was CY2013-CY2016.
A few consistent program details have carried over:
Participants can add and drop bundles at the end of 2020, signifying a one-year commitment.
Episode Initiators eligible for the program still are acute care hospitals (ACHs) and physician group practices (PGPs).
The discount applied to the benchmark price to calculate the target price is still 3%.
The stop-loss/gain is still set at 20%.
Clinical Quality Score impact is still capped at 10% in 2020 (Model Year 3).
This is subject to change in future model years; participants have the option to select between "Administrative Quality Measures Set" or "Alternate Quality Measures Set."
There are no time-based precedence rules; new entrants to the program abide by the same attribution methodology as current participants.
CMS has also added five new bundles to the program, making for a total of 37 clinical episodes: 33 inpatient and four outpatient.
New inpatient bundles:
Inflammatory Bowel Disease
Transcatheter Aortic Valve Replacement (TAVR) – Archway has been advocating that CMS split TAVR from the cardiac valve bundle
New outpatient bundle:
Outpatient Total Knee Arthroplasty (TKA) – Announced in March
What We're Still Waiting For
CMS will release more information about the program over the next eight weeks. Some things we are looking for:
Trigger diagnosis-related groups (DRGs) for new bundles
Target pricing for outpatient TKA bundle
Hierarchy with other programs (e.g. ACO Basic, Enhanced, etc.)
Details on the Alternative Quality Measure Set
Whether CMS will modify the percutaneous coronary intervention (PCI) bundle for staged TAVR procedures
Other Points of Interest
CMS is considering whether to modify the model to incentivize the use of cardiac rehabilitation (CR) and intensive CR services for BPCI Advanced cardiac clinical episodes, and intends to provide further information regarding the CR incentive prior to June 24. Additionally, CMS is implementing a simplified process for allowing current participants to restructure applications for Model Year 3. At this time, CMS does not plan to allow providers to drop from the program “risk free,” as they did with Cohort 1 participants.
There is a lot of information to digest with the opening of Cohort 2, and there’s even more to come, but rest assured that Archway is here to help. Join our webinar, “What’s New for Cohort 2” on Monday, 4/29 at 2 pm EST for a deeper dive and a chance to ask us questions.
If you’re considering the program, our BPCI Advanced Scorecard is an opportunity analysis that will arm you with personalized performance data to help you assess whether your organization is ready to join the program.