On January 9, the federal Centers for Medicare and Medicaid Services (CMS) announced a new voluntary episode payment model: Bundled Payments for Care Improvement (BPCI)-Advanced. The implementation of BPCI-Advanced follows the cancellation late last year of proposed Advanced APMS (the Episode Payment Models [EPMs] and the Cardiac Rehabilitation [CR] incentive payment models), which were scheduled for implementation in 2018. BPCI-Advanced will qualify as an Advanced Alternative Payment Model (APM) under the Quality Payment Program (QPP). Advanced APM participants may be excluded from MIPS reporting and payment adjustments and qualify for a five percent incentive payment.
BPCI-Advanced is a voluntary bundled payment model featuring a single retrospective bundled payment and one-risk track, with a 90-day clinical episode duration. BPCI-Advanced will test 29 inpatient clinical episodes and three outpatient clinical episodes. CMS has selected seven quality measures for the BPCI- Advanced Model. Two of them, All-cause Hospital Readmission Measure and Advance Care Plan, will be required for all clinical episodes. The other five quality measures will only apply to select clinical episodes.
For the purposes of BPCI-Advanced, a participant is defined as an entity that enters into a participation agreement with CMS to participate in the model. BPCI-Advanced will require downside financial risk of all participants from the outset of the model performance period.
An entity may participate as either a convener participant or a non-convener participant. A convener participant is a type of participant that brings together multiple downstream entities, referred to as “Episode Initiators (EIs).” A convener participant facilitates coordination among its EIs and bears and apportions financial risk under the model.
A non-convener participant is a participant that is in itself an EI and does not bear risk on behalf of multiple downstream EIs.
The following entities can participate as a non-convener participant:
- Acute care hospitals
- Physician group practices
The following entities can participate as a convener participant:
- Eligible entities that are Medicare-enrolled providers or suppliers
- Eligible entities that are not enrolled in Medicare
- Acute care hospitals
- Physician group practices
The BPCI-Advanced application portal will open January 11, 2018 and close March 12, 2018. The first cohort of participants will start participation in the model October 1, 2018, and the model period performance will run through December 31, 2023. CMS will provide a second application opportunity in January 2020.
A detailed CMS fact sheet on the BPCI-Advanced program can be found at https://innovation.cms.gov/Files/fact-sheet/bpci-advanced-generalfs.pdf.