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Associations Express Concerns to CMS over BPCI Advanced Model

January 26, 2018
by Rajiv Leventhal
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Leading healthcare associations are asking Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma to provide more information around the recently-announced voluntary Bundled Payment for Care Improvement-Advanced (BPCIA) model while also outlining concerns they have with its implementation.

Earlier this month, CMS announced that the BPCI Advanced model will qualify as an Advanced Alternative Payment Model (Advanced APM) under MACRA’s Quality Payment Program. “CMS is proud to announce this administration’s first Advanced APM,” CMS Administrator Seema Verma said in a statement. “BPCI Advanced builds on the earlier success of bundled payment models and is an important step in the move away from fee-for-service and towards paying for value. Under this model, providers will have an incentive to deliver efficient, high-quality care.”

The model performance period for BPCI Advanced starts on October 1, 2018 and runs through December 31, 2023.

Now, in a letter written to Verma from the Premier Healthcare Alliance, America’s Essential Hospitals, and the Association of American Medical Colleges, the organizations said that while they are pleased that BPCIA is a voluntary model that is available nationally and will qualify as an Advanced APM, they do have some concerns.

They wrote, “Generally, the information included in the request for applications (RFA) and Frequently Asked Questions (FAQ) lacks sufficient detail for clinicians and hospitals to determine if they should enter the model. For example, it is unclear how target prices will be calculated and/or adjusted, how quality scores will impact reconciliation, and when reconciliation will occur. Moreover, the RFA indicates in several areas that CMS may make modifications in future years. Participants should be provided detailed information about the model prior to the application deadline.”

As such, the organizations noted that like many Innovation Center models, this one, too, will require changes over time; however, CMS should provide a detailed description of the model. Model information should be comparable to the level of information provided in proposed and final rules for the Comprehensive Care for Joint Replacement (CJR) model, they attested.

Given that model participants “do not have adequate information at this time, we ask that CMS release detailed programmatic information by February 15 and delay the application deadline from March 12 to March 31, 2018.” They wrote, “We believe this approach will provide applicants with comprehensive information about the model without delaying the model start date. Additionally, we ask that CMS provide another opportunity to enter the model prior to 2020. Applicants should have the option to apply and enter the program for the second performance period in 2019.”

Additionally, they stated, “the RFA does not discuss in detail the model’s approach for rebasing benchmark prices over time. In the FAQs, the Innovation Center stipulates that target prices will be rebased annually, although it is unclear when the first rebasing will occur. When developing a rebasing methodology, CMS must take great care not to progressively lower target prices at an untenable rate. Rebasing methodologies pose the risk of creating a race to the bottom, that is, lowering targets to such an extent that providers will have no further efficiencies to realize and will struggle to break even. We believe that prices should be trended forward yet remained otherwise unchanged for the initial one to two years of a program.”

The healthcare associations then went on to list several ways in which CMS can improve on its implementation and build of the model, including:

Considering more equitable attribution methods, such as considering the role of the physicians who are part of the hospital group compared to those of the physician group or developing a plurality of services model. At a minimum, CMS should employ the time-based precedence rules used in BPCI.

  • More clarity around timeframes, including: performance years; benchmark years; and reconciliation.
  • Making data available early with access provided to all participants.
  • Providing more information on the composite quality score adjustment amount
  • Recognizing additional learning system activities
  • Allowing hospital-led APMs to qualify as MIPS APMs

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