AHA to CMS: Delay application deadline for new bundled payment model

Providers have until March 12 to apply for CMS’s new Bundled Payments for Care Improvement (BPCI) Advanced model, though the program was only unveiled on Jan. 9. Considering the details CMS has given about the model, that’s not enough time for hospitals to decide whether to participate, according to the American Hospital Association (AHA).

In a letter to CMS Administator Seema Verma, MPH, the AHA’s executive vice president, Thomas Nickels asked the agency to delay the application deadline to April 16 and lay out more specifics about the model.

“CMS’s announcement of BPCI Advanced and the corresponding materials raise important questions for our members about the model’s implementation,” Nickels wrote. “Of particular concern is the lack of sufficient operational detail about the model, making it difficult for hospitals and clinicians to make well-informed decisions as to participation.”

Nickels requested extra information on what target prices—calculated based on historical Medicare fee-for-service expenditures—will be past the model’s first two years, as well as how composite quality scores will be adjusted to help determine payments to participants and what Medicare Severity-Diagnosis Related Groups (MS-DRGs) will be excluded from the bundle.

The letter also suggested changes to the model itself. For example, Nickels requested participants that aren’t “conveners” in the bundled payment be allowed to participate without taking on downside risk at the start of the model.

This was the case with the original BPCI program, but those models didn’t qualify as an Advanced Alternative Payment Model under the Quality Payment Program (QPP) as the new model would.

BPCI Advanced would not, however, qualify as an APM under the Merit-based Incentive Payment System (MIPS). The AHA said CMS should reconsider this, arguing it fulfills the MIPS APM criteria for having at least one MIPS-eligible clinician on a participation list.

“CMS has provided the ability for other facility-led APMs (i.e., the Comprehensive Care for Joint Replacement, or CJR, model) to create participation lists,” Nickels wrote. “We believe this same approach should be extended to BPCI Advanced, and all other APMs (including CJR) to enable those clinicians working closely with hospitals to benefit from it. Indeed, many of these clinicians enter into financial arrangements that allow them to take on some risk for performance under the model.”