With so much to consider before deciding to apply to BPCI Advanced Cohort 2, it’s unsurprising that providers have a variety of questions. We’ve rounded up some of the more common questions we’ve received about the program, the application process, and the future.
We’ll continue to update these questions throughout the enrollment period, so come back for additional insights.
When do I have to decide if my organization will participate in BPCI Advanced?
Interested providers have until midnight, June 24, 2019 to show CMS their interest in participating in BPCI Advanced by submitting a non-binding application. Once this application period closes, CMS will distribute historical data and target prices to participating providers in September. Providers will have to make a final decision of whether or not they will participate in November, with the program starting January 1, 2020.
How does Cohort 2 differ from Cohort 1 of BPCI Advanced?
While much of Cohort 2 mirrors the first cohort of the BPCI Advanced program, there are several notable changes. With the announcement of the open enrollment window, CMS also announced five new bundles to the program, including Bariatric Surgery, Inflammatory Bowel Disease, Seizures, and Transcatheter Aortic Valve Replacement (TAVR) being added to inpatient bundles and Outpatient Total Knee Arthroplasty (TKA) being added to MJRLE. CMS is also adding an Alternative Quality Measure Set for Model Year 3.
How will OP TKA work with MJRLE?
Unlike other OP bundles, such as back and neck, except spinal fusion, cardiac defibrillator, and percutaneous coronary intervention, for which participants can select to participate in either the inpatient or outpatient bundle (or both), participants cannot select to participate in just OP TKA. Participants that opt to participate in MJRLE will have both IP and OP TKA included in their volume.
Will there be another drop option in BPCI Advanced?
There are multiple times in which providers who are currently participating can drop out of the program, including the end of 2019. Additionally, for Model Year 3 (2020), there will be options to drop out of the program. If participating providers or a new participant chooses to move forward in the program in 2020, they’ll have the option to drop out at the end of the year. However, this is not a risk-free drop option, and providers will be held accountable for any excess spending they have accrued. CMS only allowed for a risk-free drop in 2018, because the agency was late to get participating providers their historical baseline data.
Will CMS add more bundles to BPCI Advanced?
CMS has indicated that it may add more bundles to the BPCI Advanced program in the future. But because CMS has stated that this is the last application opportunity for BPCI Advanced, these new bundles will likely be limited to those providers who are already participating in the program. We also expect CMS to launch new bundled payment programs, such as a radiational oncology, which is expected to be announced this summer.
Will the baseline data to be distributed in September 2019 include all 41 episodes or only the episodes selected for Cohort 2?
Current BPCI Advanced participants will automatically receive updated baseline data for all episodes, from October 1, 2015 through September 30, 2018. This will include target prices for all episodes in which there’s sufficient volume in the baseline period, both for active Episode Initiators (EI) and any new EIs listed on the Addition Template.
When will CMS provide Secondary Repayment Source information?
Generally, for participants currently in BPCI Advanced, the convener is required to provide a Secondary Repayment Source (SRS) or establish a letter of credit for the SRS. The SRS deadline has been delayed due to the March 1stdrop deadline and Amendment to the Participation Agreement, which includes additional flexibility around the SRS requirement and is due June 1, 2019. More information about the SRS calculation for Cohort 1 is expected after this deadline passes.
Will BPCI Advanced participants receive the first reconciliation before the Participation Amendment is due for Model Year 3?
CMS has said that the first reconciliation for current BPCI Advanced participants, in Model Years 1 and 2, will occur in Fall 2019 but has not provided a more specific date. The Model Year 3 Participation Amendment will be due in November 2019. At this time, it’s unclear if current participants will receive reconciliation information prior to having to make a decision regarding their participation in Model Year 3. Archway has strongly recommended to CMS that current participants receive their initial reconciliation statements before the updated Participation Agreement is due for Model Year 3.
Will CMS change the outpatient PCI bundle to exclude TAVR?
One of our early takeaways from the March 1 withdrawal deadline was that for outpatient PCI, the staged TAVR procedures are a high-cost reason for readmission. This forced a number of groups we were working with to drop out of the bundle because readmission costs were so expensive. We’ve reviewed this issue with CMS, and we expect that before the updated Participation Agreement is due November, CMS will provide clarification on if and how they’ll modify the bundle.
Is there any new information on the Cardiac Rehab Incentive?
Cardiac Rehab (CR) is a cost currently included in the 90-day post-discharge period. Research has demonstrated improved long-term cardiovascular outcomes for patients who participated in CR therapy, particularly for those patients who attended multiple sessions. CMS has said that they are considering modifying the BPCI Advanced model to incentivize use of CR and intensive CR and will provide more detail on the CR incentive prior to June 24, 2019.
Can a hospital be both a convener and a non-convener in BPCI Advanced?
A hospital can apply as a Convener and Non-Convener Participant but can only go forward under one Participation agreement. For a hospital to be a Convener Participant, it must have at least one Downstream Episode Initiator.
Can episode initiators drop or add bundles after January 2020?
If you’re currently participating in BPCI Advanced as a part of Cohort 1, you can drop bundles at the end of 2019 and again at the end of 2020. For new participants joining as a part of Cohort 2 on January 1, 2020 you can drop out of bundles at the end of 2020.
CMS has stated that they may add new bundles to the program in the future, and if they do, live participants will be able to add those bundles to their program. It remains unclear if participants will have the option of adding current bundles later in the program.
To learn more about BPCI Advanced and have your questions about the program answered, register for one of our upcoming webinars.