BPCI Advanced FAQs
These are the frequently asked questions we’ve been fielding about the Centers for Medicare and Medicaid Services’ (CMS’) Bundled Payments for Care Improvement (BPCI) Advanced program. The application window opened April 24, and will close June 24, 2019.
Should I apply for BPCI Advanced in Spring 2019?
Yes; applying to participate in BPCI Advanced is non-binding. Most hospitals have significant economic opportunity in at least one bundle. Applying in Spring 2019 will grant you access to your claims data and final Target Prices (issued per bundle per hospital) which you can then analyze to construct your bundle portfolio and decide whether you want to participate in the program or not. If your subsequent application and agreement is approved by the CMS Center for Program Integrity (CPI), the second cohort participation will begin on January 1, 2020. Additionally, should you choose to partner with Avant-garde Health, we can make the process easy by completing and submitting the application on your behalf, and helping you construct your bundle portfolio.
What are my options for participating in BPCI Advanced?
There are two ways to participate in BPCI Advanced: (1) Convener Participant or (2) Non-Convener Participant. The former brings together multiple downstream entities, referred to as Episode Initiators (EIs), facilitates coordination among them and bears and apportions financial risk. A Non-Convener participant is an EI itself and therefore bears full risk on behalf of itself, rather than on behalf of multiple downstream EIs. If you’re not sure which option you’d prefer, you can always submit two applications – one as a Non-Convener Participant and the other with a Convener – and choose your status later.
How do I know which BPCI Advanced Clinical Episodes (i.e. bundles) to choose?
The ideal BPCI Advanced bundles for your organization will be those where you have improvement opportunities in (1) decreasing inpatient costs (e.g. utilization of implants and other supplies such as pharmaceuticals), (2) decreasing post-acute care utilization through appropriate patient risk stratification and discharge planning, (3) improving selection of top-performing post-acute care providers where relevant, (4) managing patient readmissions through well designed care pathways and (5) improving performance across the quality measures laid out in the program. And overall, these improvement opportunities decrease your cost per episode (per bundle) in relation to the CMS Target Price (per bundle). Avant-garde Health offers a complimentary evaluation of the opportunity in participating in BPCI Advanced using CMS preliminary Target Prices.
How is the reconciliation amount determined for BPCI Advanced bundles?
CMS will semi-annually reconcile all non-excluded Medicare FFS expenditures for a clinical episode against the final Target price for that clinical episode, retrospectively. This results in either a Positive Reconciliation Amount or a Negative Reconciliation Amount, since this program is a two-sided risk model. However, reconciliation payments will be capped at 20%, limiting both the upside benefit and the downside risk to participation.
If our organization is participating in another payment model, can we still participate in BPCI Advanced?
The general rule here is that you can enroll concurrently in BPCI Advanced and other shared savings initiatives, such as the Medicare Shared Savings program, or the Oncology Care Model (OCM). However, CMS prevents BPCI Advanced payments for some ACO beneficiaries, including those aligned to a Next Generation ACO and Track 3 MSSP ACO. Acute Care Hospitals (ACH) or Physician Group Practices (PGP) also participating in Comprehensive Care for Joint Replacement (CJR) or Comprehensive End Stage Renal Disease Care (CEC) will have to exclude those Medicare beneficiaries covered under the respective aforementioned programs.
Have more questions? Request a custom analysis of your health system’s projected performance in the program.