In an anticipated move, the Centers for Medicare & Medicaid Services (CMS) formally canceled the three new mandatory bundles (heart attacks, bypass surgery, and hip fracture episodes), originally scheduled for January 1, 2018 implementation. Additionally, CMS made official its intention to make the current mandatory joint replacement bundling program optional in half of the existing 67 markets. In response to comments, CMS reiterated its intent to provide an opportunity for another round of voluntary bundling.
Commenters on the original CMS proposal questioned whether CMS is pulling back from value-based payment. The agency’s response, excerpted here, takes dead aim at this concern:
However, we take seriously the commenters’ concerns about the urgency of continuing our movement toward value-based care in order to accommodate an aging population with increasing levels of chronic conditions, while also acting as responsible stewards of the Medicare Trust Funds. We continue to believe that value-based payment methodologies will play an essential role in lowering costs and improving quality of care, which will be necessary in order to maintain Medicare’s fiscal solvency. At this time, we believe that focusing on the development of different bundled payment models and engaging more providers in these models is the best way to drive health system change while minimizing provider burden and maintaining patient access to care.
Another round of voluntary bundling could be more impactful than the now canceled mandatory bundles for at least three reasons: voluntary participants are more motivated to make the necessary care transformation; the payment model is likely to transition to behavior-changing, two-sided risk more quickly than the mandatory models;, and the potential reach of voluntary bundling could be much larger in terms of clinical categories and geography. There will be changes to the voluntary program to make it meet the criteria of an advanced alternative payment method, such as explicit linkage of quality performance to shared savings, and likely tweaks to target pricing and other program features as well.
CMS’ statement about “engaging more providers” in these models is of particular interest; the mandatory models only had hospitals as the designated risk-bearing entity. In the current form of voluntary bundling (known as Bundled Payments for Care Improvement – BPCI), physicians and post-acute care also play big roles as risk-taking entities.
We are eagerly anticipating the details of the next round of voluntary bundling, which CMS reiterated would be released in a similar fashion to the last round – through a solicitation and not through formal rule making. When the last request came out in 2014, there was an application and a relatively short time frame to respond before the window closed which caused many providers to feel left out. Now is the time to plan ahead.
Stay tuned to Health Dimensions Group for more information about how these proposed changes affect providers and what you can do to prepare for these emerging opportunities. For more information, please visit www.healthdimensionsgroup.com/services or contact us at 763.537.5700 or firstname.lastname@example.org.
Authored by: Brian Ellsworth, Director, Payment Transformation