BPCI Advanced represents CMS's fourth recent foray into payment bundling, illustrating the agency's continuing interest in episode-oriented payment reform. The cancellation of the Episode Payment Models (EPMs) and the partial rollback of the Comprehensive Care for Joint Replacement (CJR), both mandatory programs, cast into doubt CMS's commitment to payment reform focused on reducing episodic costs. The announcement of BPCI Advanced—the long-awaited follow-up to the initial BPCI program—shows that the new administration believes that aligning financial incentives across the continuum of care, particularly on a voluntary basis, can be a path for reducing costs and improving quality in fee-for-service Medicare. (Subsequently, the new HHS Secretary Alex Azar has indicated that CMS may take another look at mandatory models, too.)
In many ways, BPCI Advanced is a straightforward extension of the previous program. The now-familiar 90-day retrospective bundle platform covers 29 of the highest volume inpatient services from the initial program. But the new program has also broadened its scope to include three outpatient procedures. CMS has also introduced refinements—such as including costs from unrelated readmissions within the bundle and scrapping the risk-free introductory period, to name only two. The net result of the changes may be that providers find financial success in the new model even harder to achieve than before. But the new model merits serious attention, because unlike the initial BPCI program, it meets Advanced Alternative Payment Model criteria, thus providing a vehicle for many specialists to avoid the Merit-based Incentive Payment System (MIPS) and access bonus payments under MACRA. Organizations need to seriously consider BPCI Advanced within the context of their overall MACRA strategy.
The bottom line
With the March 12 deadline fast approaching, providers will need to act quickly if they want to participate. But since providers will have a chance to review their Target Prices before deciding to sign a binding Participation Agreement, interested providers can initiate the application process—and request critical episodic spending data—without risk. Interested providers should visit CMS's BPCI Advanced website for application materials, bundle definitions, and other information. For Advisory Board's own analysis of the program, please view our on-demand webconference, "BPCI Advanced: Everything You Need to Know."
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