08 Jul HCTTF Joins Coalition Letter Urging CMMI to Support BPCI Advanced Programs
The Health Care Transformation Task Force joined an industry coalition letter urging the Center of Medicare and Medicaid Innovation to amend several programmatic areas to ensure the continuation of robust participation in BPCI Advanced (BPCI-A) and protect the investments that our health care delivery system has made to support the programs.
While options provided in early June reflect a creative approach to support BPCI-A programs as well as CMS, we believe that further assessment and development of the following actions would provide a more well-rounded and comprehensive approach:
- Provide Downside risk protection while still allowing programs to achieve up to 60% of their total NPRA earnings consistent with other bundled programs (e.g., CJR). This will support each program’s ability to fund the clinical and administrative support required to participate in the BPCI-A program while protecting participants from the unknown impacts of the COVID-19 pandemic.
- Option to remove Sepsis and Simple Pneumonia and other Respiratory Infections bundles to expand on “removal of COVID-19.” This would allow participants to continue care redesign efforts that drive continued engagement of providers and beneficiaries to achieve the demonstrated clinical outcomes for other clinical episodes while eliminating exposure to the two bundles that will see the greatest impact from the COVID-19 pandemic.
- Utilize the ICD-10 codes of B97.29 and U07.1 for the identification of qualified clinical episodes that would be excluded for MY3 if the participant were to select option 2. This would provide clear and direct support for participants to make confident decisions when it comes to protection related to the COVID-19 pandemic.
- Give participants the flexibility to forgo reconciliation for either Performance Period 3 or 4 separately, in addition to the ability to forgo episodes of care. The impact of COVID has varied widely among providers and patients; participants at risk in multiple bundles should be given flexibility to apply amendments at the bundle level.
- Promote greater stability and predictability for participants as well as for CMS by establishing and maintaining the baseline pricing for a multi-year period to reduce program uncertainty. Baseline prices should remain fixed for the initial five years, subject only to trending, to allow clinicians and hospitals to continue their investments in processes and people needed to deliver high-quality health care.
- Consider adjusting the prospective trend factor on an annual basis by employing a retrospective adjustment when actual trends vary a specific degree (e.g., +/- 0.02) from prospective estimates. The COVID pandemic is an extreme example of how this validation could retrospectively account for these dramatic changes in care patterns, which could not have been and were not contemplated in the methodology pre-COVID.
- Provide participants sufficient time to make informed decisions as it relates to options associated with impacted episodes initiated during the first few months of the pandemic which will end their clinical episode between June and August, therefore allowing participants to better analyze the impact of this unprecedented pandemic has had on their program volume through at minimum introductory claims information.
- Extend the program though CY 2024, therefore supporting the investments in infrastructure made by participants while also allowing participants to continue their long-term focus on innovative, value-based care redesign.
Geisinger Health System
Health Care Transformation Task Force
Houston Methodist Coordinated Care
NWMomentum Health Partners
Physicians of Southwest Washington
Post Acute Analytics
Trinity Health Corporation