While much of Cohort 2 will mirror the first round of BPCI Advanced, CMS has already made some adjustments for the next group that will start the program on January 1, 2020. As they continue to announce updates, we’ll keep you informed here on our live blog. Come back weekly to check for new updates.
Clarification on application of quality measures to CQS in Model Years 1 and 2
After receiving questions from participants regarding the application of the BPCI Advanced quality measures Perioperative Care: Selection of Prophylactic Antibiotic: First or Second Generation Cephalosporin and Advanced Care Plan to the Composite Quality Score (CQS) for Model Years 1 and 2.
In an email CMS stated: “…for MY1 and 2, only Quality Data Codes (QDCs) submitted for Clinical Episode Anchor Discharges occurring between July and December 2019 will be used to calculate CQS scores for these two measures.”
Info for current BPCI Advanced participants continuing in Model Year 3
In an email, CMS stated: “Current Participants that would like to continue participating as is for Model Year 3, do not need to take any action during the application period. However, they will need to submit a Participation Agreement and Participant Profile in November 2019 and other Model deliverables in December 2019.”
Changes to the overlap policy for Shared Savings Program’s (SSP) Pathways to Success
To accommodate SSP changes that will be implemented on July 1, 2019, CMS is modifying the existing overlaps policy to account for the impact of Pathways to Success on current BPCI Advanced participants.
In reconciliation, episode costs for beneficiaries assigned to Tracks 1, 1+, 2 and BASIC track will be included, while episode costs for beneficiaries aligned to the ENHANCED track will be excluded. This policy change will be applicable through the end of Model Year 2, until December 31, 2019.
CMS is still considering how to approach the model overlap between BPCI Advanced and Pathways to Success for Model Year 3 of BPCI Advanced, which begins January 1, 2020.
CMS announces open window for Cohort 2
CMS announced 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.
CMS has also added four new inpatient bundles:
Inflammatory Bowel Disease
Transcatheter Aortic Valve Replacement (TAVR) (read what we wrote about TAVRs last month)
TKA added to outpatient bundles
BPCI Advanced currently consists of 32 bundled clinical episodes (29 inpatient and 3 outpatient). In Cohort 2, CMS will add a new selection of clinical episodes to Model Year 3, which will include outpatient Total Knee Arthroplasty (TKA).
Orthopedic practices in Cohort 1 saw a decline in major lower joint (MJRLE) volume as a result of total knee replacements being reimbursed as hospital outpatient visits, which were not an eligible outpatient bundle in Cohort 1. Adding TKA to outpatient clinical episodes will help many practices with this volume issue, and offer a new opportunity for providers to practice innovation and care redesign to improve quality and reduce expenditures.
Changes to the Secondary Repayment Source (SRS) Requirement for PGPs
The original BPCI Advanced Participation Agreement required convener participants or non-convener participants that were a physician group practice (PGP) to put a specified Secondary Repayment Source (SRS) amount in an escrow account or establish a letter of credit for the guaranteed SRS amount. For PGPs, the sizable SRS requirement created significant cash-flow challenges. Prior to the March 1, 2019 deadline to drop from the program risk-free, CMS announced an amendment to the Participation Agreement to remove the SRS requirement for non-convener participants that were PGPs, in acknowledgement that CMS had authority to recoup BPCI Advanced debt owed under BPCI Advanced through ongoing Medicare payments. This amendment is one example of how CMS incorporates feedback from participants to make ongoing improvements to its alternative payment programs.