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Our Take on the BPCI Request for Application Announcement

Summary

The Centers for Medicare & Medicaid Services (CMS) have released a Request for Application (RFA) for the Bundled Payments for Care Improvement (BPCI) Advanced Initiative.

This voluntary episode payment model will begin on October 1, 2018. Applications to participate are due on March 12, 2018.

The BPCI Advanced model is the latest model to emerge from CMS that focuses on using bundled payments to improve the quality and efficiency of care for an episode of care. This model will encompass 29 inpatient and 3 outpatient clinical episodes, including 90 days of post-discharge care.

Physicians who participate in BPCI Advanced can potentially qualify as an Advanced Alternative Payment Model (APM) participant and earn a bonus under the new Medicare physician payment system created by Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

Avalere Health experts offer the following observations of the newly announced BPCI Advanced Program:

  • BPCI Advanced will count as an Advanced APM under MACRA, which will allow physicians to qualify for the 5% bonus payment under MACRA.
  • CMS requires participants to accept downside risk at the outset of the program, thus eliminating the phase-in period seen in previous bundled payment initiatives. Participants will not have an opportunity to gain experience with the model or clinical conditions prior to accepting risk. Participants will not be allowed to add or remove clinical conditions until January 1, 2020.
  • BPCI Advanced is limited to hospital and PGP participants, unlike the current BPCI program, which allowed participation across hospital, physician group practices (PGP), and post-acute care (PAC) participants.
  • Unlike previous models, the bonuses and penalties that participants earn under BPCI Advanced will be adjusted based on their performance on quality measures.
  • Post-acute and other downstream providers may enter into financial arrangements with hospitals and physician groups, further increasing the opportunity for new cross-continuum partnerships.

“The BPCI Advanced announcement makes two things clear. First, contrary to conventional wisdom, the current Administration strongly endorses the bundled payment model. Second, the inclusion of BPCI Advanced as an Advanced APM creates a powerful incentive for physicians to venture into episodic bundling,” said Fred Bentley, vice president at Avalere.

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