CMS Approves Bundled Payment For Care Improvement – Advanced (BPCI-A)

BPCI Advanced and the Environment of Alternative Payment

In this past year, the healthcare industry has seen a range of changes in Alternative Payment Models (“APM’s”) from the Centers for Medicare and Medicaid Services (“CMS”). ACO acceleration, MACRA clarification, EPM cancellation, and CJR mandatory market contraction have all led to confusion about the path ahead for alternative payment models.

When CMS announced in August 2017 the cancellation of mandatory episodic payment programs, it also doubled-down on its commitment to voluntary episodic programs. “…Many providers are currently engaged in voluntary initiatives with CMS, and we expect to continue to offer opportunities for providers to participate in voluntary initiatives, including episode-based payment models.”

The expectation of a new voluntary episodic model was then re-confirmed in CMS’ EPM final rule announced December 20, 2017. Specifically, CMS stated “…Building on the BPCI initiative, the [CMS] Innovation Center intends to implement a new voluntary bundled payment model for CY 2018 where the model(s) would be designed to meet the criteria to be an Advanced APM [for APM qualification in MACRA.]” (2)

The cancellation of EPM and the reduction of mandatory CJR participants had led many to assume that alternative payment models in general – and bundles in particular – are less important going forward. In our opinion, this assumption is dangerously limited. Mark Twain once told a newspaper that reported of his death that “the reports of my death are greatly exaggerated.” (3) He could have said the same thing about the false narrative surrounding episodic payment models.

On January 9th, 2018, CMS made its formal announcement of Bundled Payment for Care Improvement Advanced (BPCI-A). This announcement is clear confirmation that CMS is committed to the growth of alternative payment models in general and voluntary bundles in particular.

CMS also announced an application process with a March 12, 2018, deadline creating a short window for acute care hospitals and physician groups to respond as applicants. The application process is non-binding and creates a limited time opportunity to evaluate and decide if participation in a voluntary bundling program is a strategic fit, a competitive advantage, a clinical improvement opportunity, a financial opportunity, or all of these.

Finally, it’s clear that participation in BPCI Advanced can play a central role in your organization’s overall journey to risk capability. DHG Healthcare believes that, whether defined by explicit strategic planning or actual execution, virtually all markets in the United States are now operating in a post-tipping-point environment. As demonstrated by the following graphic, this means creation of operational playbooks that enable, for your specific organization and your specific market, your game plan for achieving risk capability that is responsive to your unique execution beyond the tipping point. Strong consideration of BPCI Advanced participation (including, at a minimum, "no-harm no-foul" participation in the application process) is accretive to such goals.