Last August the Centers for Medicare and Medicaid Services (CMS) provided a one-time retroactive opportunity to withdraw in total from the BPCI Advanced program or withdraw selected clinical episodes by March 1, 2019. This grace period allowed participants to “test the waters” between October 2018 and February 2019 before making a final decision. Participants that retroactively withdraw in total or for select clinical episodes will not be held accountable for those episodes. Meaning that any losses incurred relative to the established target prices will not be charged to the bundler.
This grace period is coming to a close and participants now need to make a decision as to whether to continue in the program at all and if they continue then decide which clinical episodes will work best for them over the long term. Participants can then withdraw from the other clinical episodes with no financial penalty. However, BPCI Advanced participants must be aware that if they withdraw completely from the program, then they will not be allowed to reapply during the next enrollment period that is scheduled for the Spring of 2019 (for participation beginning January 1, 2020).
Unfortunately, the CMS data received thus far does not contain enough episode volume to help participants make an informed decision. Because of the 90-day episode period, only episodes that were initiated during the month of October will have been completed at the time of the last CMS data pull, and even those episodes will require at least another couple of months to receive most all claims that were incurred during the episode period in order to determine a net reconciliation amount. Therefore, we do not recommend making a decision based on the performance period data received to date.
The work that applicants put in to evaluating clinical episodes and developing care redesign ideas last summer should be the plan for moving forward. The BPCI Advanced program was designed to encourage both high and low-cost providers to participate and to reward participants’ improvement over time. The ability to improve episode of care performance will be required of all BPCI Advanced participants in order to be successful in the program.