AHA asks CMS to delay application deadline for new bundled-payment model
The American Hospital Association urged the CMS this week to provide more details on its newest voluntary bundled-payment model and to delay the deadline to apply so hospital leaders have more time to consider participating.
In a letter to the agency, the AHA recommended the CMS make available more information by March 1 and then delay the application deadline from March 12 to April 16.
The CMS didn't respond to a request for comment on the AHA's recommendations.
The CMS announced the Bundled Payments for Care Improvement-Advanced Model in January, and said the first cohort for the model would begin Oct. 1 and run through Dec. 31, 2023.
In the letter, Thomas Nickels, AHA's executive vice president of government relations and public policy, said while the AHA supported the BPCI-Advanced Model, more information on the program design is needed so its members can make "well-informed decisions."
The letter specifically called on the CMS to give clinicians more information on the methodology used to change target prices under the model. While the CMS provided target price specifications for years 1 and 2 of the model, target prices for future model years weren't provided, the AHA said.
Additionally, the CMS indicated that it will adjust target prices semi-annually. The AHA urged the agency "to provide a detailed methodology for how it will re-base target prices and to ensure that any re-basing methodologies do not progressively lower target prices at an unachievable rate," Nickels said.
The AHA also requested more details about how quality measures will be scored under the model, specifically how the measures will be adjusted and benchmarked.
Clarification on which which quality measures will be applied to each clinical episode was requested as well. The BPCI-Advanced Model includes 32 clinical-care episodes that providers can choose from, 29 of which are in the inpatient setting and three in the outpatient setting.
The AHA said it was concerned that some of the proposed quality measures are "poorly aligned with the care episodes and patient populations." For example, the letter points out that the advanced care plan measure is required for all clinical episodes, but can technically only be applied to physicians groups because it hasn't been endorsed by the National Quality Forum for hospital use.
The AHA criticized some aspects of the BPCI-Advanced Model in the letter like the inclusion of the hospital-wide readmission measure.
"If the CMS is intent on using the hospital-wide readmission measure in the BPCI Advanced model, we strongly urge the agency to re-test the measure for reliability and validity when applied to just those patients in the care episode," Nickels wrote.
Similar to many stakeholders, the AHA supported the fact that the BPCI-Advanced Model will be considered an advanced-alternative payment model under MACRA although the AHA was "disappointed" that the model isn't considered a MIPS-APM, which makes reporting criteria easier for doctors.
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