What’s next for CMS bundled payments?

Important upcoming CMS BPCIA dates

Here are important BPCIA dates you’ll want on your radar in the coming months:

• September 2023: At the beginning of the month, CMS will upload preliminary BPCIA Model Year 7 episode target prices and baseline episode and claims data on the CMS Enterprise Portal. As a provider, you will need to use these data to evaluate which clinical episode service line groups you want to participate in during the new model year.
• Dec. 4, 2023: Providers who choose to move forward in the model have until this date to submit their MY7 Participation Agreement and Participant Profile, which will indicate selected episode initiators and clinical episode service line groups.
• Jan. 1, 2024: Model Year 7 begins. Hospitals and physician group practices that signed the participation agreement will form BPCIA’s third cohort.

3 things to do now to prepare

Providers interested in moving forward in the BCPIA model should consider taking these three steps before Dec. 4:

1. Ensure ongoing buy-in from leaders and key members.

You’ve worked hard to get initial BPCIA buy-in from clinical leaders and other key members of the operations and financial team. Now, it’s time you re-engage them so you have their support and input when choosing which clinical episode service line groups to go at risk for in BCPIA.

2. Set up your analysis strategy.

You’re going to need robust data analysis throughout the model year. Right now, you need to pay close attention to clinical episode service line groups that have achievable target prices and enough actionable episode expenditures to be successful. Because this analysis function requires advanced technical skills and a quick turnaround time, you’ll need to ensure you have the right people in place to handle the task.

If your organization can’t support the effort internally, we suggest working with an external partner like DataGen. We can provide specific BPCIA solutions that allow you to analyze episode targets, comprehend key metrics, identify patterns in your episode spend and understand your post-acute care utilization.

3. Develop the framework to meet other BPCIA participation requirements.

To hit the ground running on Jan. 1, 2024, you’ll need multiple departments within your organization to be engaged. This includes a process for quality measure data collection, sending beneficiary notification letters, implementation of the care redesign plan and more. If you need assistance developing your framework, DataGen provides model education along with our BPCIA solution that can help you get the infrastructure you need to get set up for success.

The future of Medicare bundles after CJR and BPCIA

Earlier in the summer, the Center for Medicare and Medicaid Innovation and CMS solicited input on the design of a future episode-based payment model. By Aug. 17, stakeholders had the chance to submit public comments to CMS on the design of a future episode-based payment model.

CMS was looking for answers to these questions:

• Which clinical episodes should be tested and how long should they be?
• What considerations should be made about the types of potential participants?
• Which quality measures are the most valuable across care settings?
• How should CMS balance the need for predictable, achievable target prices with the need to create net Medicare savings?
• How can CMS allow beneficiary overlap with ACO initiatives yet ensure incentives are not being paid double for the same beneficiary?
  

What does this mean for providers?

A major reason CMS asked for public input was to help the agency figure out a way to design an episode-based payment model that co-exists with accountable care organizations in a complementary way.

The overall goal to incentivize providers using episode-based payment models will remain the same. Providers will still need to demonstrate that they can coordinate patient care in a manner that avoids duplicative or unnecessary services and reduces gross Medicare spending. 

However, the future of this model would include mandatory participation by providers in certain geographic regions and would begin no earlier than 2026, after both BPCIA and the Comprehensive Care for Joint Replacement program have ended. Any future mandatory model will go through the rule-making process and will allow sufficient time for participants to prepare.

Need help preparing? DataGen can help.

Success in bundled payment models requires all hands on deck. If you need a partner who has experience in alternative payment models, you can rely on DataGen.

Leveraging 30+ years of knowledge, our healthcare data experts can help you understand the program methodology and what is driving your results. Contact us today to see how we can help or request a free demo.