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Bundled Payments for Care Improvement:
Overview and Basic Parameters
CMS Center for Medicare and
Medicaid Innovation (CMMI)
Bundled Payments for Care
Improvement Team
March 11, 2014
Agenda
• Review principles for Bundled Payments for
Care Improvement (BPCI)
• Why should physicians be engaged?
• New and current engagement opportunities
for Physicians
2
Why Engage as a Provider?
• Meaningful gainsharing opportunities, up to 50%
more than physician fee schedule equivalent.
• Does not impact fee for service payment under
Models 2 and 3.
• Competencies learned in bundled payment
position physicians for success in value-based
contracting.
• Facilitates physician leadership in care redesign.
• Opportunity to work and learn from others
nationally and receive data.
3
How can physicians or physician group
practices further engage?
• Speak to hospitals, post-acute care providers and current
existing awardees where they admit patients.
• Check website for entities participating in their regions
listed on the CMMI website.
• Be aware of opportunities to join current awardees and
new prospective participants through the Winter Open
Period and quarterly processes.
• Find archived resources for physicians at:
http://innovation.cms.gov/initiatives/Bundled-
Payments/learning-area.html and https://air-
event500.webex.com/air-
event500/onstage/g.php?t=a&d=594120927.
• Email inbox with questions.
4
Delivery Transformation Continuum
Providers choose from a range of
care delivery transformations
with escalatingamountsof risk, whilebenefitingfrom
supports and resources designed tospread best practices and
improve care.
The Patient-centered
Health Care System
of the future
5
The Case for Bundled Payments
• Large opportunity to reduce costs from waste and variation
• Gainsharing incentives align hospitals, physicians and post-
acute care providers in the redesign of care that achieves
savings and improves quality
• Improvements “spillover” to private payers
• Strategies learned in bundled payments lay the foundation for
success in a value driven market
• Adoption of bundled payments is accelerating across both
private and public payers
• Valuable synergies with ACOs, Medicare’s Shared Savings
Program and other payment reform initiatives
6
Rationale for BPCI Episode Parameters
BPCI Episodes Parameters:
– Allow flexibility for providers to select clinical conditions,
time frames, and services with greatest opportunity for
improvement
– Enable episodes that have sufficient numbers of
beneficiaries to demonstrate meaningful results
– Assure enough simplicity to allow rapid analysis and
implementation of episode definitions
– Achieve episodes with the appropriate balance of financial
risk and opportunity
– Build on lessons from prior initiatives and CMS
demonstrations
7
Clinical Episodes
Acute myocardial infarction Major bowel procedure
AICD generator or lead Major cardiovascular procedure
Amputation Major joint replacement of the lower extremity
Atherosclerosis Major joint replacement of the upper extremity
Back & neck except spinal fusion Medical non-infectious orthopedic
Coronary artery bypass graft Medical peripheral vascular disorders
Cardiac arrhythmia Nutritional and metabolic disorders
Cardiac defibrillator Other knee procedures
Cardiac valve Other respiratory
Cellulitis Other vascular surgery
Cervical spinal fusion Pacemaker
Chest pain Pacemaker device replacement or revision
Combined anterior posterior spinal fusion Percutaneous coronary intervention
Complex non-cervical spinal fusion Red blood cell disorders
Congestive heart failure Removal of orthopedic devices
Chronic obstructive pulmonary disease, bronchitis, asthma Renal failure
Diabetes Revision of the hip or knee
Double joint replacement of the lower extremity Sepsis
Esophagitis, gastroenteritis and other digestive disorders Simple pneumonia and respiratory infections
Fractures of the femur and hip or pelvis Spinal fusion (non-cervical)
Gastrointestinal hemorrhage Stroke
Gastrointestinal obstruction Syncope & collapse
Hip & femur procedures except major joint Transient ischemia
Lower extremity and humerus procedure except hip, foot, femur Urinary tract infection
8
Bundled Payments Models
Blank Model 2:
Retrospective Acute
Care Hospital Stay
plus Post-Acute Care
Model 3: Retrospective
Post-Acute Care Only
Model 4:
Prospective Acute
Care Hospital Stay
Only
Episode Selected DRGs +post-
acute period
Post acute only for
selected DRGs
Selected DRGs
Services
included in
the bundle
Part A and B services
during the initial
inpatient stay, post-
acute period and
readmissions
Part A and B services
during the post-acute
period and readmissions
All Part A and B
services (hospital,
physician) and
readmissions
Payment Retrospective Retrospective Prospective
9
Model 2 Background
• Participants choose one or more of the 48 episodes and select a length
of each episode (30, 60 or 90 days)
• Episodes are initiated by the inpatient admission of an eligible Medicare
FFS beneficiary to an acute care hospital for one of the MS-DRGs
included in a selected episode
• Model 2 episode-based payment includes inpatient hospital stay for the
anchor DRG
• Includes related care covered under Medicare Part A and Part B within
30, 60, or 90 days following discharge from acute care hospital
• Episode-based payment is retrospective
– Medicare continues to make fee-for-service (FFS) payments to providers and
suppliers furnishing services to beneficiaries in Model 2 episodes
– Total payment for a beneficiary’s episode is reconciled against a bundled
payment amount (the target price) predetermined by CMS
10
Current Model 2 Participants
Map and list available at http://innovation.cms.gov/initiatives/BPCI-Model-2/index.html 11
Model 2 Illustrative Timeline
12
Model 3 Background
• Participants choose one or more of the 48 episodes and select a length of each
episode (30, 60 or 90 days)
• Episode begins at initiation of post-acute services with a participating skilled
nursing facility (SNF), inpatient rehabilitation facility (IRF), long-term care hospital
(LTCH), or home health agency (HHA) following an acute care hospital stay for an
anchor MS-DRG or the initiation of post-acute care services where a member
physician of a participating physician group practice (PGP) was the attending or
operating physician for the beneficiary’s inpatient stay.
• Post-acute care services included in the episode must begin within 30 days of
discharge from the inpatient stay and end either a minimum of 30, 60, or 90 days
after the initiation of the episode
• Episode includes post-acute care following an inpatient acute care hospital stay
and all related care covered under Medicare Part A and Part B within 30, 60, or 90
days following initiation of post-acute services
• Episode-based payment is retrospective
– Medicare continues to make fee-for-service (FFS) payments to providers and suppliers
furnishing services to beneficiaries in Model 3 episodes
– Total payment for a beneficiary’s episode is reconciled against a bundled payment amount
(the target price) predetermined by CMS
13
Model 3 Participants
Map and list available at http://innovation.cms.gov/initiatives/BPCI-Model-3/index.html
14
Model 4 Background
• Participants choose one or more of the 48 episodes
• Each episode is initiated by an acute care hospital inpatient
admission for one of the MS-DRGs included in an episode selected
for participation by the Episode Initiator. Episode initiators submit a
Notice of Admission (NOA) when a beneficiary expected to be
included in the model is admitted
• Bundled payment includes all Medicare Part A and Part B covered
services furnished during the inpatient stay by the hospital,
physicians, and nonphysician practitioners, as well as any related
readmissions that occur within 30 days after discharge
• Episode-based payment is prospective
– CMS makes a single, predetermined bundled payment to the Episode
Initiator (an acute care hospital) instead of an Inpatient Prospective
Payment System (IPPS) payment
15
Declining Participation in Model 4:
Physicians and Non-physician Practitioners
• Physicians or non-physician practitioners will be
able to decline participation in Model 4 and be
paid regular FFS for Part B services rendered
during an inpatient stay.
– Declinations will be per service
– Part B claim must be submitted with a HCPCS modifier
on every relevant line
– Payment will flow as normally, and coinsurance can be
collected as normally by physician or non-physician
practitioner
16
Model 4 Participants
Map and list available at http://innovation.cms.gov/initiatives/BPCI-Model-4/index.html
17
Submission Types:
Description of Roles
Submission Type
Risk-Bearing
Awardee Convener
Non Risk-Bearing
Single Awardee
(Episode Initiator)
Designated Awardee
(Episode Initiator)
This entity takes risk
under the facilitator
convener.
Designated Awardee
Convener
This entity takes risk
under the facilitator
convener.
Facilitator Convener
Episode Initiator Episode Initiator
18
Non Risk-Bearing
A BPCI participant is a Facilitator Convener if it will not bear risk
but would like to facilitate other organizations (called Designated
Awardees and Designated Awardee Conveners) that take risk for
redesigning care under an episode payment model.
19
Submission Type: Facilitator Convener
• Who would submit intake forms?
– Organizations that wish to perform a facilitative role
without bearing risk or receiving payment from CMS
• Which beneficiaries are they responsible for?
– Each designated awardee/designated awardee convener is
responsible, per the definitions in the former slides
• What kind of partners would they have?
– Designated awardees
– Designated awardee conveners
20
Risk-Bearing Awardees
A BPCI participant is an Awardee if it is a Medicare
provider that bears risk for only episodes that it
initiates.
A BPCI participant is an Awardee Convener if it
applies with partners and bears risk for all episodes
of its episode initiator partners.
21
Submission Type: Awardee
• Who would submit as this type of applicant?
– Example: Individual hospital
• Which beneficiaries are they responsible for?
– Only their own Bundled Payment patients
– All of their own Bundled Payment patients,
regardless of the other providers where these
patients receive care during the episode
22
Submission Type: Awardee Convener
• Who would submit in this role?
– Parent companies, health systems, and other organizations
that wish to take risk
• Which beneficiaries are they responsible for?
– All of their own bundled payment beneficiaries during the
episode if the Awardee Convener is a Medicare provider,
regardless of the other providers where these patients receive
care during the episode
– All bundled payment beneficiaries of the Episode Initiators,
regardless of the other providers where these patients receive
care during the episode
• What kind of partners would they have?
– Episode-initiators
23
Physician Group Practices
• For the purposes of BPCI, we define a
physician group practice with the following
requirements:
– A unique EIN/TIN combination for the PGP. More
than one practitioner
– All practitioners that have reassigned their
individual NPI to the PGP for billing purposes.
This ensures that the group in its entirety is
participating in BPCI
24
Physician Group Practices as Episode
Initiators
– Models 2: Acute care hospitals and physician group practices
• When a PGP is an Episode Initiator, an episode is initiated when a physician
in the PGP is the admitting or ordering physician for the acute or post acute
care for an eligible beneficiary for an included MS-DRG, regardless of the
particular hospital where the beneficiary is admitted. All physicians that
reassign their Medicare benefits to the PGP initiate episodes
– Model 3: Skilled nursing facilities, long-term care hospitals, inpatient
rehabilitation facilities, home health agencies, physician group
practices
• When a PGP is an Episode Initiator, an episode is initiated when an eligible
beneficiary is admitted to or initiates services with a SNF, IRF, LTCH, or HHA
within 30 days after the beneficiary has been discharged from an inpatient
stay at an ACH for one of the included MS-DRGs and a physician in the PGP
was the attending or operating physician for the inpatient ACH stay
– Model 4: Acute care hospitals Acute care hospitals paid under the
Inpatient Prospective Payment System (IPPS)
25
Current BPCI Participants by type
Participant Type
Facilitator Convener 9
Single Awardee 27
Designated Awardee Convener (DAC) 3
Awardee Convener (AC) 38
Episode Initiators (under DAC or AC)* 255
Provider Type
Acute Care Hospital 165
Skilled Nursing Facility 63
Home Health Agency 86
Physician Group Practice 8
Long term care hospital 1
Inpatient Rehabilitation Facility 1
Physician engagement continues to grow.
26
BPCI Phases
Phase 1 Phase 2
Following the April 2014 submission, new participants
are selected for Phase 1. Phase 1 is the risk-bearing
phase. Phase 1 represents the initial period of
participant preparation for implementation and
assumption of financial risk
Phase 2 is the risk-bearing period.
Selection is based on CMS’ review and acceptance of
proposed care redesign plans and program integrity
screening.
To move into Phase 2 as an Awardee, participants must
be selected by CMS following a comprehensive review
and enter into an agreement with CMS.
Participants receive:
 Monthly beneficiary-level claims data
 Engagement in variety of learning activities with
other BPCI Phase 1 and Phase 2 participants.
 Target pricing information to inform assessments of
opportunities under BPCI.
 Assessment of opportunities under BPCI.
Agreements allow awardees to:
 Bear financial risk for the model
May utilize applicable fraud and abuse waivers
and payment policy waivers (i.e. gainsharing)
27
Evaluation and Monitoring
• CMS intends to measure metrics including:
– structural and organizational characteristics
– patient case-mix
– clinical care and patient safety
– patient experience
• CMS also monitors utilization and compliance within
agreements, fraud and abuse waivers, and Medicare payment
policy waivers.
28
Fraud and Abuse Waivers
• Waivers of certain fraud and abuse authorities are available in
Phase 2 for specified gainsharing, incentive payment, and
patient engagement incentive arrangements in connection
with BPCI Models 2-4, except as otherwise provided in a BPCI
Models 2-4 Awardee’s agreement with CMS.
29
Payment Policy Waivers
3-Day Hospital Stay Requirement for SNF Payment (Model 2)
• CMS waives the requirement in section 1861(i) for a 3-day inpatient hospital
stay prior to the provision of Medicare covered post-hospital extended care
services. For purposes of this waiver, a majority of skilled nursing facilities
(SNFs) that the Awardee is partnering with must have a three star or better
overall quality rating under the CMS 5-Star Quality Rating System, as
reported on the Nursing Home Compare website, for at least 7 out of the 12
months immediately preceding the performance period. All other
provisions of the statute and regulations regarding Medicare Part A post-
hospital extended care services continue to apply.
Telehealth (Models 2, 3)
• Section 1834(m) of the Act allows Medicare payment for telehealth services
where the originating site is one of eight healthcare settings that is located
in a geographic area that satisfies certain requirements. CMS waives the
geographic area requirement for telehealth services furnished to eligible
beneficiaries during a Model 3 episode, as long as the services are furnished
in accordance with all other Medicare coverage and payment criteria.
30
Payment Policy Waivers continued
Post-Discharge Home Visit (Models 2, 3)
• CMS waives the direct supervision requirement in 42 C.F.R. § 410.26(b)(5) for
“incident to” services, provided that such services are furnished as follows:
• The services are furnished to a beneficiary who does not qualify for Medicare
coverage of home health services under 42 C.F.R. § 409.42, and the services are
furnished in the beneficiary’s home after the beneficiary has been discharged from
an Episode Initiator;
• The services are furnished by licensed clinical staff under the general supervision of
a physician or other practitioner as defined in 42 C.F.R. § 410.32(b)(3)(i);
• The services are furnished by licensed clinical staff and billed by the physician or
other practitioner using a Healthcare Common Procedures Coding System (HCPCS)
G-code specified by CMS;
• The services are furnished not more than once in a 30-day episode, not more than
twice in a 60-day episode, and not more than three times in a 90-day episode; and
• The services are furnished in accordance with all other Medicare coverage and
payment criteria, including the remaining provisions of 42 C.F.R. § 410.26(b).
31
Engage Now:2014 Winter Open Period
Models 2, 3 and 4
• CMS announced the opportunity for additional
organizations to be considered for participation in
BPCI and current participants to expand their
existing activities.
• Background documents for Models 2 – 4, intake
forms located at:
http://innovation.cms.gov/initiatives/Bundled-
Payments/Models2-4OpenPeriod.html.
• Submissions are due to CMS for consideration by
April 18, 2014 by email via:
BundledPayments@cms.hhs.gov.
32
Winter 2014 Open Period Timeline for
New Participants
33
Winter 2014 Open Period Timeline for
New Participants (continued)
34
Questions
Thank you for your time.
Any questions that are not answered during this session
can be submitted to BundledPayments@cms.hhs.gov.
Background Documents and Additional Information
Found at:
http://innovation.cms.gov/initiatives/bundled-payments/
http://innovation.cms.gov/initiatives/Bundled-
Payments/Models2-4OpenPeriod.html.
35

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Webinar: Bundled Payments for Care Improvemement Initiative - Overview and Parameters

  • 1. Bundled Payments for Care Improvement: Overview and Basic Parameters CMS Center for Medicare and Medicaid Innovation (CMMI) Bundled Payments for Care Improvement Team March 11, 2014
  • 2. Agenda • Review principles for Bundled Payments for Care Improvement (BPCI) • Why should physicians be engaged? • New and current engagement opportunities for Physicians 2
  • 3. Why Engage as a Provider? • Meaningful gainsharing opportunities, up to 50% more than physician fee schedule equivalent. • Does not impact fee for service payment under Models 2 and 3. • Competencies learned in bundled payment position physicians for success in value-based contracting. • Facilitates physician leadership in care redesign. • Opportunity to work and learn from others nationally and receive data. 3
  • 4. How can physicians or physician group practices further engage? • Speak to hospitals, post-acute care providers and current existing awardees where they admit patients. • Check website for entities participating in their regions listed on the CMMI website. • Be aware of opportunities to join current awardees and new prospective participants through the Winter Open Period and quarterly processes. • Find archived resources for physicians at: http://innovation.cms.gov/initiatives/Bundled- Payments/learning-area.html and https://air- event500.webex.com/air- event500/onstage/g.php?t=a&d=594120927. • Email inbox with questions. 4
  • 5. Delivery Transformation Continuum Providers choose from a range of care delivery transformations with escalatingamountsof risk, whilebenefitingfrom supports and resources designed tospread best practices and improve care. The Patient-centered Health Care System of the future 5
  • 6. The Case for Bundled Payments • Large opportunity to reduce costs from waste and variation • Gainsharing incentives align hospitals, physicians and post- acute care providers in the redesign of care that achieves savings and improves quality • Improvements “spillover” to private payers • Strategies learned in bundled payments lay the foundation for success in a value driven market • Adoption of bundled payments is accelerating across both private and public payers • Valuable synergies with ACOs, Medicare’s Shared Savings Program and other payment reform initiatives 6
  • 7. Rationale for BPCI Episode Parameters BPCI Episodes Parameters: – Allow flexibility for providers to select clinical conditions, time frames, and services with greatest opportunity for improvement – Enable episodes that have sufficient numbers of beneficiaries to demonstrate meaningful results – Assure enough simplicity to allow rapid analysis and implementation of episode definitions – Achieve episodes with the appropriate balance of financial risk and opportunity – Build on lessons from prior initiatives and CMS demonstrations 7
  • 8. Clinical Episodes Acute myocardial infarction Major bowel procedure AICD generator or lead Major cardiovascular procedure Amputation Major joint replacement of the lower extremity Atherosclerosis Major joint replacement of the upper extremity Back & neck except spinal fusion Medical non-infectious orthopedic Coronary artery bypass graft Medical peripheral vascular disorders Cardiac arrhythmia Nutritional and metabolic disorders Cardiac defibrillator Other knee procedures Cardiac valve Other respiratory Cellulitis Other vascular surgery Cervical spinal fusion Pacemaker Chest pain Pacemaker device replacement or revision Combined anterior posterior spinal fusion Percutaneous coronary intervention Complex non-cervical spinal fusion Red blood cell disorders Congestive heart failure Removal of orthopedic devices Chronic obstructive pulmonary disease, bronchitis, asthma Renal failure Diabetes Revision of the hip or knee Double joint replacement of the lower extremity Sepsis Esophagitis, gastroenteritis and other digestive disorders Simple pneumonia and respiratory infections Fractures of the femur and hip or pelvis Spinal fusion (non-cervical) Gastrointestinal hemorrhage Stroke Gastrointestinal obstruction Syncope & collapse Hip & femur procedures except major joint Transient ischemia Lower extremity and humerus procedure except hip, foot, femur Urinary tract infection 8
  • 9. Bundled Payments Models Blank Model 2: Retrospective Acute Care Hospital Stay plus Post-Acute Care Model 3: Retrospective Post-Acute Care Only Model 4: Prospective Acute Care Hospital Stay Only Episode Selected DRGs +post- acute period Post acute only for selected DRGs Selected DRGs Services included in the bundle Part A and B services during the initial inpatient stay, post- acute period and readmissions Part A and B services during the post-acute period and readmissions All Part A and B services (hospital, physician) and readmissions Payment Retrospective Retrospective Prospective 9
  • 10. Model 2 Background • Participants choose one or more of the 48 episodes and select a length of each episode (30, 60 or 90 days) • Episodes are initiated by the inpatient admission of an eligible Medicare FFS beneficiary to an acute care hospital for one of the MS-DRGs included in a selected episode • Model 2 episode-based payment includes inpatient hospital stay for the anchor DRG • Includes related care covered under Medicare Part A and Part B within 30, 60, or 90 days following discharge from acute care hospital • Episode-based payment is retrospective – Medicare continues to make fee-for-service (FFS) payments to providers and suppliers furnishing services to beneficiaries in Model 2 episodes – Total payment for a beneficiary’s episode is reconciled against a bundled payment amount (the target price) predetermined by CMS 10
  • 11. Current Model 2 Participants Map and list available at http://innovation.cms.gov/initiatives/BPCI-Model-2/index.html 11
  • 12. Model 2 Illustrative Timeline 12
  • 13. Model 3 Background • Participants choose one or more of the 48 episodes and select a length of each episode (30, 60 or 90 days) • Episode begins at initiation of post-acute services with a participating skilled nursing facility (SNF), inpatient rehabilitation facility (IRF), long-term care hospital (LTCH), or home health agency (HHA) following an acute care hospital stay for an anchor MS-DRG or the initiation of post-acute care services where a member physician of a participating physician group practice (PGP) was the attending or operating physician for the beneficiary’s inpatient stay. • Post-acute care services included in the episode must begin within 30 days of discharge from the inpatient stay and end either a minimum of 30, 60, or 90 days after the initiation of the episode • Episode includes post-acute care following an inpatient acute care hospital stay and all related care covered under Medicare Part A and Part B within 30, 60, or 90 days following initiation of post-acute services • Episode-based payment is retrospective – Medicare continues to make fee-for-service (FFS) payments to providers and suppliers furnishing services to beneficiaries in Model 3 episodes – Total payment for a beneficiary’s episode is reconciled against a bundled payment amount (the target price) predetermined by CMS 13
  • 14. Model 3 Participants Map and list available at http://innovation.cms.gov/initiatives/BPCI-Model-3/index.html 14
  • 15. Model 4 Background • Participants choose one or more of the 48 episodes • Each episode is initiated by an acute care hospital inpatient admission for one of the MS-DRGs included in an episode selected for participation by the Episode Initiator. Episode initiators submit a Notice of Admission (NOA) when a beneficiary expected to be included in the model is admitted • Bundled payment includes all Medicare Part A and Part B covered services furnished during the inpatient stay by the hospital, physicians, and nonphysician practitioners, as well as any related readmissions that occur within 30 days after discharge • Episode-based payment is prospective – CMS makes a single, predetermined bundled payment to the Episode Initiator (an acute care hospital) instead of an Inpatient Prospective Payment System (IPPS) payment 15
  • 16. Declining Participation in Model 4: Physicians and Non-physician Practitioners • Physicians or non-physician practitioners will be able to decline participation in Model 4 and be paid regular FFS for Part B services rendered during an inpatient stay. – Declinations will be per service – Part B claim must be submitted with a HCPCS modifier on every relevant line – Payment will flow as normally, and coinsurance can be collected as normally by physician or non-physician practitioner 16
  • 17. Model 4 Participants Map and list available at http://innovation.cms.gov/initiatives/BPCI-Model-4/index.html 17
  • 18. Submission Types: Description of Roles Submission Type Risk-Bearing Awardee Convener Non Risk-Bearing Single Awardee (Episode Initiator) Designated Awardee (Episode Initiator) This entity takes risk under the facilitator convener. Designated Awardee Convener This entity takes risk under the facilitator convener. Facilitator Convener Episode Initiator Episode Initiator 18
  • 19. Non Risk-Bearing A BPCI participant is a Facilitator Convener if it will not bear risk but would like to facilitate other organizations (called Designated Awardees and Designated Awardee Conveners) that take risk for redesigning care under an episode payment model. 19
  • 20. Submission Type: Facilitator Convener • Who would submit intake forms? – Organizations that wish to perform a facilitative role without bearing risk or receiving payment from CMS • Which beneficiaries are they responsible for? – Each designated awardee/designated awardee convener is responsible, per the definitions in the former slides • What kind of partners would they have? – Designated awardees – Designated awardee conveners 20
  • 21. Risk-Bearing Awardees A BPCI participant is an Awardee if it is a Medicare provider that bears risk for only episodes that it initiates. A BPCI participant is an Awardee Convener if it applies with partners and bears risk for all episodes of its episode initiator partners. 21
  • 22. Submission Type: Awardee • Who would submit as this type of applicant? – Example: Individual hospital • Which beneficiaries are they responsible for? – Only their own Bundled Payment patients – All of their own Bundled Payment patients, regardless of the other providers where these patients receive care during the episode 22
  • 23. Submission Type: Awardee Convener • Who would submit in this role? – Parent companies, health systems, and other organizations that wish to take risk • Which beneficiaries are they responsible for? – All of their own bundled payment beneficiaries during the episode if the Awardee Convener is a Medicare provider, regardless of the other providers where these patients receive care during the episode – All bundled payment beneficiaries of the Episode Initiators, regardless of the other providers where these patients receive care during the episode • What kind of partners would they have? – Episode-initiators 23
  • 24. Physician Group Practices • For the purposes of BPCI, we define a physician group practice with the following requirements: – A unique EIN/TIN combination for the PGP. More than one practitioner – All practitioners that have reassigned their individual NPI to the PGP for billing purposes. This ensures that the group in its entirety is participating in BPCI 24
  • 25. Physician Group Practices as Episode Initiators – Models 2: Acute care hospitals and physician group practices • When a PGP is an Episode Initiator, an episode is initiated when a physician in the PGP is the admitting or ordering physician for the acute or post acute care for an eligible beneficiary for an included MS-DRG, regardless of the particular hospital where the beneficiary is admitted. All physicians that reassign their Medicare benefits to the PGP initiate episodes – Model 3: Skilled nursing facilities, long-term care hospitals, inpatient rehabilitation facilities, home health agencies, physician group practices • When a PGP is an Episode Initiator, an episode is initiated when an eligible beneficiary is admitted to or initiates services with a SNF, IRF, LTCH, or HHA within 30 days after the beneficiary has been discharged from an inpatient stay at an ACH for one of the included MS-DRGs and a physician in the PGP was the attending or operating physician for the inpatient ACH stay – Model 4: Acute care hospitals Acute care hospitals paid under the Inpatient Prospective Payment System (IPPS) 25
  • 26. Current BPCI Participants by type Participant Type Facilitator Convener 9 Single Awardee 27 Designated Awardee Convener (DAC) 3 Awardee Convener (AC) 38 Episode Initiators (under DAC or AC)* 255 Provider Type Acute Care Hospital 165 Skilled Nursing Facility 63 Home Health Agency 86 Physician Group Practice 8 Long term care hospital 1 Inpatient Rehabilitation Facility 1 Physician engagement continues to grow. 26
  • 27. BPCI Phases Phase 1 Phase 2 Following the April 2014 submission, new participants are selected for Phase 1. Phase 1 is the risk-bearing phase. Phase 1 represents the initial period of participant preparation for implementation and assumption of financial risk Phase 2 is the risk-bearing period. Selection is based on CMS’ review and acceptance of proposed care redesign plans and program integrity screening. To move into Phase 2 as an Awardee, participants must be selected by CMS following a comprehensive review and enter into an agreement with CMS. Participants receive:  Monthly beneficiary-level claims data  Engagement in variety of learning activities with other BPCI Phase 1 and Phase 2 participants.  Target pricing information to inform assessments of opportunities under BPCI.  Assessment of opportunities under BPCI. Agreements allow awardees to:  Bear financial risk for the model May utilize applicable fraud and abuse waivers and payment policy waivers (i.e. gainsharing) 27
  • 28. Evaluation and Monitoring • CMS intends to measure metrics including: – structural and organizational characteristics – patient case-mix – clinical care and patient safety – patient experience • CMS also monitors utilization and compliance within agreements, fraud and abuse waivers, and Medicare payment policy waivers. 28
  • 29. Fraud and Abuse Waivers • Waivers of certain fraud and abuse authorities are available in Phase 2 for specified gainsharing, incentive payment, and patient engagement incentive arrangements in connection with BPCI Models 2-4, except as otherwise provided in a BPCI Models 2-4 Awardee’s agreement with CMS. 29
  • 30. Payment Policy Waivers 3-Day Hospital Stay Requirement for SNF Payment (Model 2) • CMS waives the requirement in section 1861(i) for a 3-day inpatient hospital stay prior to the provision of Medicare covered post-hospital extended care services. For purposes of this waiver, a majority of skilled nursing facilities (SNFs) that the Awardee is partnering with must have a three star or better overall quality rating under the CMS 5-Star Quality Rating System, as reported on the Nursing Home Compare website, for at least 7 out of the 12 months immediately preceding the performance period. All other provisions of the statute and regulations regarding Medicare Part A post- hospital extended care services continue to apply. Telehealth (Models 2, 3) • Section 1834(m) of the Act allows Medicare payment for telehealth services where the originating site is one of eight healthcare settings that is located in a geographic area that satisfies certain requirements. CMS waives the geographic area requirement for telehealth services furnished to eligible beneficiaries during a Model 3 episode, as long as the services are furnished in accordance with all other Medicare coverage and payment criteria. 30
  • 31. Payment Policy Waivers continued Post-Discharge Home Visit (Models 2, 3) • CMS waives the direct supervision requirement in 42 C.F.R. § 410.26(b)(5) for “incident to” services, provided that such services are furnished as follows: • The services are furnished to a beneficiary who does not qualify for Medicare coverage of home health services under 42 C.F.R. § 409.42, and the services are furnished in the beneficiary’s home after the beneficiary has been discharged from an Episode Initiator; • The services are furnished by licensed clinical staff under the general supervision of a physician or other practitioner as defined in 42 C.F.R. § 410.32(b)(3)(i); • The services are furnished by licensed clinical staff and billed by the physician or other practitioner using a Healthcare Common Procedures Coding System (HCPCS) G-code specified by CMS; • The services are furnished not more than once in a 30-day episode, not more than twice in a 60-day episode, and not more than three times in a 90-day episode; and • The services are furnished in accordance with all other Medicare coverage and payment criteria, including the remaining provisions of 42 C.F.R. § 410.26(b). 31
  • 32. Engage Now:2014 Winter Open Period Models 2, 3 and 4 • CMS announced the opportunity for additional organizations to be considered for participation in BPCI and current participants to expand their existing activities. • Background documents for Models 2 – 4, intake forms located at: http://innovation.cms.gov/initiatives/Bundled- Payments/Models2-4OpenPeriod.html. • Submissions are due to CMS for consideration by April 18, 2014 by email via: BundledPayments@cms.hhs.gov. 32
  • 33. Winter 2014 Open Period Timeline for New Participants 33
  • 34. Winter 2014 Open Period Timeline for New Participants (continued) 34
  • 35. Questions Thank you for your time. Any questions that are not answered during this session can be submitted to BundledPayments@cms.hhs.gov. Background Documents and Additional Information Found at: http://innovation.cms.gov/initiatives/bundled-payments/ http://innovation.cms.gov/initiatives/Bundled- Payments/Models2-4OpenPeriod.html. 35