Bundled Payments – Last Call???

Medicare’s Bundled Payment for Care Improvement (BPCI) program has seen more ups and downs than the stock market.

Here we go again! CMS seems to be pulling another about-face on Bundled Payments.

Here is what I wrote in a blog post about the program back in November 2018.

The Obama administration launched the programs and went through four models including a mandatory model (Joint Replacement). The first two Secretaries of HHS in the Trump administration decided that they didn’t like bundled payment programs and canceled two upcoming mandatory programs (care for heart attacks and for cardiac bypass surgery). But they allowed the voluntary BPCI Advanced program to go forward.

But that’s all changed. Current HHS Secretary Alex Azar has announced that the administration will be launching three new mandatory bundles because, as he put it: “We need results, American patients need change, and when we need mandatory models to deliver it, mandatory models are going to see a comeback.”

However, in their March 21 update announcing the opening of the BPCI portal for the 2020 model year, CMS said: “… CMS intends to open the application period for Model Year 3 in April 2019. The second cohort of Participants will start on January 1, 2020, which is Model Year 3. At this time, CMS does not intend to have additional enrollment periods for Model Year 4 (2021) or Model Year 5 (2022),,,,” (Italics are mine.)

What does this mean for the future of the bundled payment program? No one seems to know exactly. But here is what I do know and have been saying for a while now: We will continue to move from FFS to Value-Based Care and there will be multiple models along the way.

So, if you are running a hospital, an IPA, a PO or a large practice what do you do? How do you keep moving ahead in spite of CMS’s frequent course changes (or, as our friends in the Navy would say, these Crazy Ivans)?

The answer is not to cut the engines. Instead, think about how to deploy infrastructure that can support multiple (including currently unknown) Alternate Payment Models simultaneously. This is unlikely to be your EHR. Because no current EHR is really suited to this environment, all having been built around requirements for FFS billing. However, this exactly the kind changing environment that care management and population health platforms are designed to address as they are focused on identifying populations based on flexible parameters, and providing the tools to take action to improve health and lower costs. Those are timeless and critical goals that persist despite what seem to be never-ending changes in CMS program rules.

I would love to hear your thoughts on this and especially where I may be wrong!

About Mansoor Khan
Dr. Khan is a veteran software company CEO with broad experience in identifying market needs, building a team to answer those needs and establishing brand name excellence. He is currently the CEO of Persivia Inc., which he co-founded in 2015. Prior to Persivia Dr. Khan was the CEO of Alere Analytics, formerly DiagnosisOne, which he co-founded in 2004. Persivia currently provides care management, population health, and quality management software and services to over 250 hospitals, over 4500 physicians in outpatient settings, touching 20M patients.