CMS Announces New Voluntary Advanced Bundled Payment Model for Ten Cardiac Clinical Episodes

CMS announced on January 9, 2018 a new advanced bundled payment model for 29 inpatient and three outpatient clinical episodes.  Included are eight inpatient cardiac episodes and two outpatient cardiac episodes.  

After dropping the mandatory Cardiac Bundled Payment Model in 2017, CMS’s Center for Innovation is moving aggressively to test a new iteration for 32 total patient episodes on a voluntary basis.  Here are the facts you need to know.

• To be known as the Bundled Payment Care Improvement Advanced (BPCI Advanced) model
• The model is completely voluntary
• The following inpatient cardiac episodes are included:
  • Acute myocardial infarction
  • Cardiac arrhythmia
  • Cardiac defibrillator
  • Cardiac valve
  • Congestive heart failure
  • Coronary artery bypass graft (CABG)
  • Pacemaker
  • Percutaneous coronary intervention (PCI)
• The following outpatient cardiac episodes are included:
  • Percutaneous coronary intervention (PCI)
  • Cardiac defibrillator
• A single retrospective bundled payment and one risk track, with a 90-day clinical episode duration
• Payment is tied to performance on quality measures
  • Two measures, all-cause hospital readmission rate, and Advance Care Plan, apply to all episodes
  • Five other measures will only apply to select episodes
• Qualifies as an advanced Alternative Payment Model under the Quality Payment Program of MACRA where providers take financial risk to earn incentive payments
• Open to both acute care hospitals and physician group practices
• Preliminary Target Prices provided in advance of the first Performance Period of each Model Year
• Reconciliation will be semi-annual where CMS will compare the aggregate Medicare Fee-for-Service expenditures (including outlier payments) in a clinical episode against the Target Price for that clinical episode to determine if the participant is eligible to receive either:
  • A payment from CMS (the “upside” risk); or,
  • Is required to pay a repayment amount (the “downside” risk)
• Participation begins October 1, 2018 and runs to December 31, 2023
• Applications must be submitted electronically by March 12, 2018 at 11:59 pm EST

For complete information, visit https://innovation.cms.gov/initiatives/bpci-advanced.  Included are downloads for the Application Template, Data Request and Attestation Form, Participating Organization List and other relevant information required for participation.

As CFA predicted when the mandatory bundled pricing model was cancelled, we felt certain that CMS would introduce new voluntary models; we just didn’t know it would be this soon, or include so many cardiac episodes including some outpatient episodes.  CFA strongly recommends that all hospitals, regardless of their readiness or inclination to participate, should study the proposed model and review the Application Template in detail to familiarize themselves with this opportunity and its requirements.  Understandably, voluntary participation in risk-taking models qualifies as a significant decision with extremely impactful potential financial and clinical implications.  Make no mistake, this is the way federal payment reform is proceeding; perhaps more rapidly than we ever imagined.

CFA will continue to monitor the roll-out of the BPCI Advanced model and provide updated information and analysis in the coming weeks.

If you are interested in learning more about strategies to deal with bundled payments, low-volume cardiac surgery programs and/or programmatic assessment for cardiovascular services, please contact CFA at (949) 443-4005 or by e-mail at cfa@charlesfrancassociates.com.