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PROPRIETARY & CONFIDENTIAL – © 2016 PREMIER, INC. Welcome Advisor Live: January 23, 2018 Our Presentation: Bundled Payment for Care Improvement Advanced Will Begin Shortly Listen to Today’s Audio: 877.256.5083 Download today’s slides at www.premierinc.com/events

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Page 1: Welcome Advisor Live: January 23, 2018 - Premier, Inc.offers.premierinc.com/rs/381-NBB-525/images/AdvisorLive...PROPRIETARY & CONFIDENTIAL –© 2016 PREMIER, INC. Welcome Advisor

PROPRIETARY & CONFIDENTIAL – © 2016 PREMIER, INC.

WelcomeAdvisor Live: January 23, 2018Our Presentation:Bundled Payment for Care Improvement AdvancedWill Begin Shortly

Listen to Today’s Audio: 877.256.5083

Download today’s slides at www.premierinc.com/events

Page 2: Welcome Advisor Live: January 23, 2018 - Premier, Inc.offers.premierinc.com/rs/381-NBB-525/images/AdvisorLive...PROPRIETARY & CONFIDENTIAL –© 2016 PREMIER, INC. Welcome Advisor

PROPRIETARY & CONFIDENTIAL – © 2016 PREMIER, INC.

Advisor LiveBundled Payment for Care Improvement Advanced

January 23, 2018

@PremierHA#AdvisorLiveDownload today’s slides at www.premierinc.com/events

Page 3: Welcome Advisor Live: January 23, 2018 - Premier, Inc.offers.premierinc.com/rs/381-NBB-525/images/AdvisorLive...PROPRIETARY & CONFIDENTIAL –© 2016 PREMIER, INC. Welcome Advisor

© 2018 PROPRIETARY & CONFIDENTIAL | 3TRANSFORMING HEALTHCARE TOGETHER®

Logistics

AUDIODial in to our operator assisted call, 877.256.5083

QUESTIONSUse the “Questions and Answers”

RECORDINGThis webinar is being recorded. View it later today on the event post at premierinc.com/events.

NOTESDownload today’s slides from the event post at premierinc.com/events

Page 4: Welcome Advisor Live: January 23, 2018 - Premier, Inc.offers.premierinc.com/rs/381-NBB-525/images/AdvisorLive...PROPRIETARY & CONFIDENTIAL –© 2016 PREMIER, INC. Welcome Advisor

© 2018 PROPRIETARY & CONFIDENTIAL | 4TRANSFORMING HEALTHCARE TOGETHER®

Faculty

Aisha Pittman, M.P.H.Director, quality policy and analysisPremier, Inc.

Mark HillerVP, innovative solutionsPremier, Inc.

Justin RockDirector, performance partnersPremier, Inc.

Page 5: Welcome Advisor Live: January 23, 2018 - Premier, Inc.offers.premierinc.com/rs/381-NBB-525/images/AdvisorLive...PROPRIETARY & CONFIDENTIAL –© 2016 PREMIER, INC. Welcome Advisor

© 2018 PROPRIETARY & CONFIDENTIAL | 5TRANSFORMING HEALTHCARE TOGETHER®

Agenda

• BPCI Advanced Overview• Participants and Model Years• Inclusions and Exclusions• Episode Attribution• Payment Methodology and Price Setting• Reconciliation• Financial Arrangements• Waivers• Composite Quality Scoring• Advanced APM Participation• Premier Comments on Model• Model Overlap• Application Process

Page 6: Welcome Advisor Live: January 23, 2018 - Premier, Inc.offers.premierinc.com/rs/381-NBB-525/images/AdvisorLive...PROPRIETARY & CONFIDENTIAL –© 2016 PREMIER, INC. Welcome Advisor

© 2018 PROPRIETARY & CONFIDENTIAL | 6TRANSFORMING HEALTHCARE TOGETHER®

Bundled Payment for Care Improvement AdvancedHigh Level Overview

• Announced January 9, 2018

• Establishes 32 Clinical Episodes; 29 inpatient and 3 outpatient– Voluntary model– Two types of participants: Convener and Non-Convener– All Part A & B “related” services from hospital admission through 90 days post-discharge– Provides an estimated prospective target price prior to a given performance period– Requires 3% discount rate– Total Reconciliation Amount will be adjusted based on a Composite Quality Score (CQS)– Reconciliation will take place on a semiannual basis– Participants take on risk at the start of the program– Must participate in CMS designated Learning System activities– Model runs from October 1, 2018- December 31, 2023

• Second opt-in period available for January 1, 2020 start date– Initial application period is January 11, 2018 – March 12, 2018

• Creates an opportunity to meet requirements to be considered an Advanced APM under MACRA

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© 2018 PROPRIETARY & CONFIDENTIAL | 7TRANSFORMING HEALTHCARE TOGETHER®

BPCI Advanced Guidance Documents

Since the announcement of BPCI Advanced, CMS has provided intermittent updates on program rules.

However, much of the guidance is either incomplete or has been somewhat ambiguous.

Throughout this presentation, unless otherwise indicated, statements in black are stated with certainty. Statements in orange are ambiguous and will require additional clarification from CMS.

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© 2018 PROPRIETARY & CONFIDENTIAL | 8TRANSFORMING HEALTHCARE TOGETHER®

BPCI Advanced Reconciliation Overview

Triggers: Inpatient – “Anchor Stay” based on MS-DRGOutpatient – “Anchor Procedure” based on HCPCS

Annual Medicare spending for all BPCI Advanced episodes

Adm

issi

on

Dis

char

ge90 Days

All Medicare Part A & Part B “related” fee-for-service payments

Target price ≈ 3% discount based on historical target

Epis

ode

Rec

onci

liatio

n Pa

ymen

ts

Below spending target

Above spending target

$$$$$$$$$$$$$$$ Hospital repays Medicare $$$$$$$$$$$$$$$

$$$$$$$$$$$$$$$ Reconciliation payment to hospital $$$$$$$$$$$$$$$

QualityComposite Quality score which adjusts total reconciliation by up to 10% based on relative performance.

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© 2018 PROPRIETARY & CONFIDENTIAL | 9TRANSFORMING HEALTHCARE TOGETHER®

BPCI Advanced Key Terminology

• ACH: Acute Care Hospital

• PGP: Physician Group Practice

• Episode Initiator (EI): An ACH or PGP that participates in BPCI Advanced as either: (1) a Participant; or (2) pursuant to an Agreement with a Convener Participant under which such downstream Episode Initiator agrees to participate in BPCI Advanced. An Episode Initiator can trigger a Clinical Episode under BPCI Advanced.

• Anchor Stay: An inpatient stay at an ACH assigned to a qualifying MS-DRG code for which an Episode Initiator submits a claim to Medicare FFS, which in turn triggers a Clinical Episode.

• Anchor Procedure: A hospital outpatient procedure performed in a Hospital Outpatient Department identified by a qualifying HCPCS code for which an Episode Initiator submits a claim to Medicare FFS, which in turn triggers a Clinical Episode.

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PROPRIETARY & CONFIDENTIAL – © 2016 PREMIER, INC.10

Inpatient Bundles Anchored by MS-DRG§ Orthopedic surgery (6) – Major joint replacement of lower extremity – Major

replacement of upper extremity – Double joint replacement lower extremity – Fractures of femur & hip or pelvis – Hip & femur procedures except major joint replacement –Lower extremity/humerus procedure except hip, foot, femur

§ Ortho/Neuro surgery (4) – Cervical fusion – Spine fusion except cervical – Back & neck procedures except spinal fusion – Combined anterior posterior spine fusion

§ Cardiac (8) – Cardiac arrhythmia – CHF – AMI – Cardiac defibrillator – Cardiac valve –CABG – Pacemaker – PCI

§ Gastrointestinal (3) – Major bowel procedure – GI hemorrhage – GI obstruction§ Respiratory (2) – COPD, bronchitis, & asthma – Simple pneumonia & respiratory

infections§ Other Medical (5) – Cellulitis – Renal failure – Sepsis – Stroke – UTI§ New (1) – Disorders of the liver excluding malignancy, cirrhosis, alcoholic hepatitis

Outpatient Bundles Identified by HCPCS• Cardiac (2) – PCI – Cardiac Defibrillator• Ortho/Neuro surgery (1) – Back & Neck procedures

except spinal fusion

Blue text = medical bundle

32 Bundles in BPCI Advanced

*Bundles are italicized for ease of reading, not to denote significance

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BPCI Advanced Participants

• Includes Acute Care Hospitals (ACH) and Physician Group Practices (PGP)

• Can initiate their own episodes• Takes on risk on behalf of themselves

Non-Convener

• Includes ACHs, PGPs, Medicare enrolled providers, or non-Medicare enrolled providers

• Brings together Episode Initiators (EI) to participate in BPCI Advanced

• Cannot initiate their own episodes• Bears full financial risk on behalf of their Episode

Initiators

Convener

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© 2018 PROPRIETARY & CONFIDENTIAL | 12TRANSFORMING HEALTHCARE TOGETHER®

BPCI Advanced Model Years

• BPCI Advanced program runs from October 1, 2018 through December 31, 2023– Initial application period is January 11, 2018 – March 12, 2018

• Participants will not be able to exit BPCI Advanced or add/drop individual bundles until the end of a Model Year (MY)

• CMS may require an annual renewal of the BPCI Advanced Participation Agreement

• Second application period will be available for episodes starting January 1, 2020

• Reconciliation will occur on a semiannual basis with two true--upsMY 1October 1, 2018 to December 31, 2018

MY 2October 1, 2018 to December 31, 2019

MY 3January 1, 2020 to December 31, 2020

MY 4January 1, 2021 to December 31, 2021

MY 5January 1, 2022 to December 31, 2022

MY 6January 1, 2023 to December 31, 2023

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© 2018 PROPRIETARY & CONFIDENTIAL | 13TRANSFORMING HEALTHCARE TOGETHER®

Beneficiary Inclusion

• Beneficiaries must meet all the following criteria:− Enrolled in Medicare Part A and Part B during the entire episode− Have Medicare as their primary payer− Eligible for Medicare but not on the basis of end-stage renal

disease (ESRD)− Not enrolled in any managed care plan (for example, Medicare

Advantage, Health Care Prepayment Plans, cost-based health maintenance organizations)

− Not covered under a United Mine Workers of America health plan, which provides health care benefits for retired mine workers

− Not prospectively aligned to Next Generation ACO, MSSP Track 3 or an ACO in a track of the Comprehensive ESRD Care Initiative incorporating downside risk for financial losses

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© 2018 PROPRIETARY & CONFIDENTIAL | 14TRANSFORMING HEALTHCARE TOGETHER®

Beneficiary/Other Exclusions

• Beneficiary death during the BPCI Advanced Anchor Stay or Anchor Procedure cancels the episode

• If a beneficiary in a CJR episode overlaps at any time with what would otherwise be considered a BPCI Advanced episode, the BPCI Advanced Episode is canceled

• If a beneficiary is in an Anchor BPCI Advanced episode and is readmitted for an episode which would otherwise trigger a BPCI Advanced Episode, the readmission BPCI Advanced episode is canceled

• BPCI Advanced episode begins with initial hospitalization or procedure –not prior to admission

− NOTE: For inpatient BPCI Advanced Episodes, Episodes begin at admission. Services prior to admissions (e.g. within 72 hours) that are included in the MS-DRG payment are included in the episode, but no other services prior to admission are included.

− Example: This is important as transfers from another hospital’s ED within the three day period would not be included.

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© 2018 PROPRIETARY & CONFIDENTIAL | 15TRANSFORMING HEALTHCARE TOGETHER®

Who Can Apply to BPCI Advanced?

Non-Conveners:• ACHs and PGPs

– ACHs in CJR may apply to BPCI Advanced, but will not be eligible to participate in the Major Joint Replacement of the Lower Extremity bundle

• The following organizations are not eligible for BPCI Advanced:– Prospective Payment System (PPS) - exempt Cancer Hospitals– Inpatient Psychiatric facilities– Critical Access Hospitals– Hospitals in Maryland– Hospitals participating in the Rural Community Hospital Demonstration and Participant

Hospitals in the Pennsylvania Rural Health model– Vermont all-payer ACO participants may apply to BPCI Advanced, but beneficiaries are

excluded from BPCI Advanced

Conveners:• Medicare-enrolled provider or supplier (e.g. ACHs, PGPs, SNFs, etc.)• Entity not enrolled in Medicare (e.g. venture capitalist groups, etc.)

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© 2018 PROPRIETARY & CONFIDENTIAL | 16TRANSFORMING HEALTHCARE TOGETHER®

Episode Attribution Hierarchy

• Similar to BPCI, certain Episode Initiators will take precedence over others. Under BPCI Advanced, the hierarchy is:

1. PGP which has the Attending Provider’s NPI listed on the institutional claim and a corresponding carrier claim

2. PGP which has the Operating Provider’s NPI listed on the institutional claim and a corresponding carrier claim

3. ACH where the Anchor Stay or Anchor Procedure occurred

• Unlike BPCI, early BPCI Advanced participants do not receive attribution over later participants– Example: If an ACH starts BPCI Advanced on October 1, 2018 and a

PGP joins on January 1, 2020, the PGP will receive attribution before the ACH for future bundles

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© 2018 PROPRIETARY & CONFIDENTIAL | 17TRANSFORMING HEALTHCARE TOGETHER®

Payment Methodology

CMS has yet to publish methodology files;detailed information is limited at this time

• The Benchmark Price is calculated based on a combination of historical Medicare FFS spending, adjusted to reflect:

– Episode Initiator’s efficiency relative to its peers over time– Adjustments for patient characteristics – Regional spending trends

• Benchmark prices are adjusted for complexity (e.g. DRG)• Benchmark prices receive a 3% discount to calculate the Target

price• Uniform 90 day episode length• Uniform episode risk cap of 1st and 99th percentile

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© 2018 PROPRIETARY & CONFIDENTIAL | 18TRANSFORMING HEALTHCARE TOGETHER®

Payment Methodology (Cont’d)

• Baseline and Performance Period BPCI Advanced Episodes Exclude:

− All Part A and Part B services during certain specified ACH admissions and readmissions

» A single list for all bundles will be provided; focus will be on Transplant & Tracheostomy, Trauma, Cancer, and Ventricular Shunts

− New technology add-on payments under the IPPS− Payments for items and services with pass-through payment

status under the OPPS− Payment for blood clotting factors to control bleeding for

hemophilia patients− Certain Per Beneficiary/Per Month (PBPM) payments through

Innovation Center Programs (e.g. OCM MEOS payments)

NOTE: Unlike BPCI, BPCI Advanced will not have ambulatory Part B exclusions

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© 2018 PROPRIETARY & CONFIDENTIAL | 19TRANSFORMING HEALTHCARE TOGETHER®

Baseline for Price Setting

• Baseline is comprised of 3 years of historical data– As reported by the Data Request and Attestation File, Baseline Years will

be January 1, 2013 through December 31, 2016 for Model Year 1– Prices will be communicated prior to beginning of Model Years

» Target prices will be adjusted retrospectively at time of reconciliation to adjust for actual patient case-mix

– Prices will be set for each clinical definition

• ACHs and PGPs calculate Prices differently– ACH’s prices will be calculated based on the ACH only– PGP’s prices will be calculated based specifically to the ACH at which an

Anchor Stay or Anchor Procedure is initiated

• Reconciliation and repayment under BPCI and CJR:– It is unclear at this time whether historical prices will factor in positive and

negative NPRA associated with BPCI and CJR episodes

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© 2018 PROPRIETARY & CONFIDENTIAL | 20TRANSFORMING HEALTHCARE TOGETHER®

Reconciliation

• Reconciliation will occur on a semiannual basis with two true-ups

• Bundle-specific prospective target prices will be updated based on retrospective case mix during the performance period

• Total Reconciliation Amounts will be adjusted based on performance on quality measures at the Episode Initiator level.

• There will be a 20% stop-gain/stop-loss limit at the Episode Initiator level applied after quality measure adjustments

• Reconciliation will include post-episode monitoring to ensure there is no cost shifting to the post-episode period– Post-episode costs will be compared to the 99.5% confidence interval of

predicted spending– If Medicare FFS expenditures exceed this amount, the Participant must

pay CMS the difference

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© 2018 PROPRIETARY & CONFIDENTIAL | 21TRANSFORMING HEALTHCARE TOGETHER®

Reconciliation ExampleNon-Convener

Episode Initiator(Total Positive

Reconciliation Amount)

Bundle 1(Positive Reconciliation

Amount)

DRG A

DRG B

Bundle 2(Negative Reconciliation

Amount)

DRG D

DRG ELess: CQS Adjustment

Equals: NPRA/Adjusted Total Positive

Reconciliation Amount

Flow of Reconciliation

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© 2018 PROPRIETARY & CONFIDENTIAL | 22TRANSFORMING HEALTHCARE TOGETHER®

Reconciliation ExampleConvener

Convener(Adjusted Total Positive Reconciliation Amount)

Episode Initiator A(Adjusted Total Positive Reconciliation Amount)*

Bundle 1(Positive Reconciliation

Amount)

Bundle 2(Negative Reconciliation

Amount)

Episode Initiator B(Adjusted Total Negative Reconciliation Amount)*

Bundle 3(Positive Reconciliation

Amount)

Bundle 4(Negative Reconciliation

Amount)

Flow of Reconciliation

*CQS Adjustment is at the Episode Initiator Level

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© 2018 PROPRIETARY & CONFIDENTIAL | 23TRANSFORMING HEALTHCARE TOGETHER®

Financial Arrangements

Participants may share both positive NPRA payments and negative repayment risk with physicians and non-physician practitioners.

Two Major Types of Agreements:1. NPRA Sharing Arrangement – Direct NPRA and/or risk sharing

arrangement with eligible NPRA Sharing Partners2. Partner Distribution Agreement – NPRA and/or risk sharing

arrangement between an NPRA Sharing Partner PGP and a physician or non-physician practitioner employed by the PGP

Financial Arrangement Limits:• Positive NPRA payments and negative repayments cannot exceed 50% of

the total Medicare FFS expenditures included in clinical episodes attributed to the Participant

• Physicians and non-physician practitioners cannot be paid more than 50% of the Medicare FFS attributed to the physician or non-physician practitioner for Participant clinical episodes

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Financial Arrangements (Cont’d)

NPRA Sharing Partners may include:• Participating Practitioners

– Physician or non-physician practitioners (e.g., nurse practitioner, physician assistant, or physical therapist)

• Clinicians employed by an ACH Participant• ACHs• PGPs• ACOs• Post-Acute Providers (PACs)

NPRA Sharing Partners must 1. Participate in BPCI Advanced activities; and2. Be identified as an NPRA Sharing Partner on a Financial Arrangement

Screening List; and 3. Enter into a written NPRA Sharing Agreement that satisfies all of the

applicable requirements of the BPCI Advanced Model Participation Agreement

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© 2018 PROPRIETARY & CONFIDENTIAL | 25TRANSFORMING HEALTHCARE TOGETHER®

Waivers

CMS plans to offer the following waivers:• Fraud and Abuse Waivers: Not currently defined, but would be

released by CMS and OIG prior to the start of the Model– This may include waivers to allow Financial Arrangements with

NPRA Sharing Partners and allow for beneficiary incentives

• Telehealth Payment Policy Waiver: Waiver of the otherwise applicable geographic area requirements for BPCI Advanced Beneficiaries during the clinical episode

• Post-Discharge Home Visits Payment Policy Waiver: Waiver of the direct supervision requirement for “incident to” services for the purposes of allowing “auxiliary personnel” to provide in-home services

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© 2018 PROPRIETARY & CONFIDENTIAL | 26TRANSFORMING HEALTHCARE TOGETHER®

Waivers (Cont’d)

• SNF 3-Day Waiver: Would waive the 3-day inpatient stay requirement for SNF discharge contingent upon:– Beneficiary is discharged to a Qualified SNF as published by CMS

– Has a SNF Star Rating of 3 or above

– Identified on the list of SNFs eligible to be Qualified SNFs posted on the CMS website, as determined by CMS based on the most recent rolling 12 months of SNF Star Rating data

– Beneficiary satisfies the definition of a BPCI Advanced Beneficiary at time of discharge from the Anchor Stay

– Beneficiary has an ICD-10 Dx code, which corresponds to an MS-DRG that is included in a clinical episode to which the Participant has committed to be held accountable under BPCI Advanced

– All other coverage requirements for such services are metNOTE: In the event that the waiver is not used in accordance with the requirements above, CMS will not pay the SNF, the beneficiary is not held liable for SNF-related costs, and Participant may be liable for the cost of the SNF stay.

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Composite Quality Score

• A quality score will be calculated for each quality measure at the Clinical Episode level, if applicable

• These scores will be scaled across all Clinical Episodes attributed to a given Episode Initiator, weighted based on Clinical Episode volume, and summed to calculate an Episode Initiator-specific Composite Quality Score (CQS)

• CQS includes process and outcomes measures– Outcomes measures will be weighted more than process measures

• A CQS Adjustment Amount will be applied to the Positive or Negative Total Reconciliation Amount to calculate NPRA

• For the first two Model Years, there is a 10% cap on the amount by which the CQS will adjust reconciliation

– Adjusted Total Reconciliation Amounts will be 90 to 100 percent of the Total Reconciliation Amounts

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BPCI Advanced Quality Measures

In 2018 and 2019, CMS will collect the following required claims-based quality measures for all bundles:• All-cause Hospital Readmission Measure (NQF #1789)• Advanced Care Plan (NQF #0326) In 2018 and 2019, CMS will collect the following required claims-based quality measures for only certain specific bundles:• Perioperative Care: Selection of Prophylactic Antibiotic: First or Second

Generation Cephalosporin (NQF #0268)• Hospital-Level Risk-Standardized Complication Rate (RSCR) Following Elective

Primary Total Hip Arthroplasty (THA) and/or Total Knee Arthroplasty (TKA) (NQF #1550)

• Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate (RSMR) Following Coronary Artery Bypass Graft Surgery (NQF #2558)

• Excess Days in Acute Care after Hospitalization for Acute Myocardial Infarction (NQF #2881)

• AHRQ Patient Safety Indicators (PSI): roll-up measure

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BPCI Advanced Quality Measures (Cont’d)

In addition, non-claims based measures which may be collected after 1/1/2020 include:• CAHPS for Clinicians (NQF #0005)• CAHPS for Hospitals (NQF #0006)• CAHPS Home Health Care (NQF #0166)• Hypertension: Improvement in Blood Pressure (CMS #373)• Drug Regimen Review with Follow-up (CMS #2849)• Surgical Site Infection (SSI) (NQF #0299)• Unplanned Reoperation within the 30 Day Postoperative Period (CMS

#1966)

NOTE: If these measures are collected, they would be required to be reported by the February after the end of a Model Year.

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Advanced APM Participation

• Creates opportunity to participate as an AAPM under MACRA in 2019 MACRA Model Year/2021 MACRA payment year

• MACRA offers two types of participation in AAPMs:– Affiliated Practitioners are providers who participate in an AAPM on an

individual basis only. These Practitioners have separate agreements with the APM Entity which are independent of the agreement between CMS and the APM Entity. Any determinations of meeting AAPM thresholds will be performed at the individual provider level.

– Participating Practitioners are providers who participate in an APM through the APM Entity. These Practitioners are included in the list of Participating Practitioners submitted as part of the APM Entity agreement with CMS. Any determinations of meeting AAPM thresholds may be performed at the APM Entity and the individual provider level.

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Advanced APM Participation (Cont’d)

Affiliated PractitionersACH• Only those with NPRA Sharing Agreements may qualify for AAPM

determinations at an individual level only• Affiliated Practitioners are not eligible for MIPS APM criteria

Participating PractitionersPGP• All providers included in the PGP provider list submitted to CMS are able

to meet AAPM criteria as a group• May act as a MIPS APM if the PGP does not meet APPM thresholds

starting in 2019• Providers may still meet AAPM criteria at an individual basis in the event

the PGP does not meet AAPM thresholds

Participation in BPCI Advanced through an ACH or a PGP confers different AAPM opportunities

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QPP PY2018 – MIPS APM Scoring Standard*

50%

20%

30%

MSSP 50%

20%

30%

Next Gen

Other APM

Quality — Measures reported by APM and counts 50% towards MIPS score Web Interface measures: 14 measures, 4 receive a bonus point � 2017: 11 measures

Cost — Not assessed, BUT potential to share in savings via APM

Advancing care information — Average of individual clinicians submitting as individuals or groups;

Improvement activities — Automatically receive half of the points

50%

20%

30%

*Subject to change based on QPP 2019 Final Rules

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Premier Comments on BPCI Advanced

• Release detailed programmatic information by February 15– Delay the application deadline from March 12 to March 31, 2018

• Allow providers an option to begin the model with no or lower downside risk– Lower the stop-loss limits in the initial year from 20 percent to 10 percent

to ease the transition to greater risk

• Provide a detailed methodology for how CMS will determine the benchmark and target prices– Prices should be trended forward yet remained unchanged for the initial

one to two years of a program

• Consider more equitable attribution approaches: role of hospital and physician group physicians, plurality of services– Employ time-based precedence rules like those used in BPCI

• Clarify timelines: performance years, benchmark years, reconciliation

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Premier Comments on BPCI Advanced (Cont’d)

• Release detailed episode and data specifications as soon as possible, and no later than May– Allow participants who elect to participate under BPCIA Conveners to access

their own programmatic data

• Provide detailed information on the CQS Adjustment approach– Reward good and exceptional quality performance with a lowered discount

on the target price

– Provide a detailed CQS methodology that is specific to each type of episode initiator and includes benchmarks, scoring and data collection requirements

– Do not include PSI-90 in BPCIA until ICD-10 specifications are available

– Allow participants to attest to participation in non-CMS learning systems or improvement activities that are specific to bundled payments

• Use a consistent approach for who is considered a participant under Advanced APMs and MIPS APMs

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BPCI Advanced Overlap With Value Based Models

• Beneficiaries in the following programs are excluded from BPCI Advanced entirely– Next Generation ACO

– Vermont All-Payer ACO

– ESRD Seamless Care Organization

– MSSP Track 3 ACO

• CJR episodes take precedence over BPCI Advanced• Oncology Care Model (OCM) incorporates any positive or negative

reconciliation under BPCI Advanced into OCM expenditures prorated for the amount of time of overlap

– Example: BPCI Advanced episode had a positive reconciliation of $10,000. The episode overlapped for 50% of the BPCI Advanced episode with an OCM episode. The OCM episode will have $5,000 added to the episode cost ($10,000 * 50%).

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BPCI Advanced Application Process

The application includes 10 sections with multiple narrative questions included in each section:

1. Provide organizational information including an executive summary of the application2. Describe plans to engage, retain and involve practitioners in care redesign3. Discuss care improvement including care redesign plans and a readiness assessment of your

organization4. Explain previous gainsharing experience and document proposed NPRA sharing methodology and

plans5. Describe plans for quality improvement including CEHRT attestation and explain prior improvement

initiative experience6. Include methods for quality assurance procedures 7. Share plans for beneficiary protection with program notification, engagement and involvement8. Discuss financial arrangements including any plans to share or delegate financial risk9. Explain your organization’s capabilities and readiness for bundled payments and plans for resource

allocation and program operations10. Describe your organization’s partner relationships and their collaboration on care redesign

The application also requires:• Data Request and Attestation (DRA) form• Certification

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BPCI Advanced Application Timeline

Request for application (RFA) released

January 9, 2018

Application portal is open January 11, 2018 – March 12, 2018

CMS screens applicants March – June 2018

CMS distributes target prices to applicants

May 2018

CMS offers participation agreements to applicants

June 2018

Signed participation agreements due to CMS

August 2018

Clinical episode selections and program deliverables due to CMS

August 2018

Model go-live October 1, 2018

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BPCI Advanced Application Logistics and Reminders

• Apply via the BPCI Advanced Application portal which is accessible through the Innovation Center website: https://innovation.cms.gov/initiatives/bpci-advanced/

• Complete and submit your application through the interface of the portal. – Note that the PDF application on the CMMI BPCI Advanced website is only a

template and is not meant to be completed outside of the portal– Portal allows copy/paste function, but no upload abilities– No email application submissions will be accepted

• Submit the Data Request and Attestation (DRA) form along with the application

• Participants cannot receive historical data unless they submit the DRA with the BPCI Advanced Application

• Application portal will remain open until March 12, 2018 at 11:59PM EST.

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BPCI Advanced: Don’t Delay and Act Now

What you need to do by March 12, 2018: Step 1: Quantify your opportunities. Request a Premier BPCI Advanced Episode Opportunity Analysis (EOA). We will conduct a call with your team to help you evaluate your opportunity.

Step 2: Submit your application. There is no obligation to participate. By doing so you will be able to assess your opportunity. Premier has years of experience helping providers improve their revenue and margins by applying to CMS bundled payment programs.

CMS Application: https://innovation.cms.gov/Files/x/bpciadvanced-application.pdf.Step 3: Get in Wave 1. Beat the competition! If you don’t get in, other providers could commoditize your hospitals.

Why you need to participate:• Increase revenue and margins through bundled payments.

• Glean insights from the data with no obligation to CMS. Expect data by May 2018.

• BPCI Advanced will support participation as an Advanced Alternative Payment Model (AAPM), earning a 5% bonus.

• Premier has led the way with hundreds of hospitals and physician groups in both CMS bundled payment models (e.g. BPCI, CJR, OCM) and non-CMS bundles to improve costs.

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BPCI Advanced Application Support – What to Expect From Premier

• Application Best Practice Language: We will provide best practice language for the narrative questions included in the BPCI Advanced application. Please note this language will be a recommended guide for completing the narrative questions, but will require you finish the application with details specific to your organization.

• Application Office Hours: Scheduled weekly calls to begin on February 13. We will send dial-in information once you contact us.

• Portal Registration: Detailed instructions will be provided on how to register for the CMMI BPCI Advanced portal where you will submit your application and Data Request & Attestation (DRA) form.

• Data Request & Attestation (DRA) Form: Detailed instructions will be provided on how to complete the DRA form to ensure your organization receives all available data.

• Episode Opportunity Assessment (EOA): Premier will offer members an EOA report that will provide an analysis of the 29 inpatient conditions of the BPCI Advanced program. This will include both episode level and MS-DRG level analysis and national benchmark comparisons on cost and utilization. Premier anticipates these reports will be available in early February.

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Questions

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Faculty

Aisha Pittman, M.P.H.Director, quality policy and analysisPremier, Inc. [email protected]

Mark HillerVP, innovative solutionsPremier, [email protected]

Justin RockDirector, performance partnersPremier, [email protected]

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Appendix

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BPCI Advanced Activities

For the purposes of Financial Arrangements, NPRA Sharing Partners must participate in BPCI Advanced Activities.

These activities would include:• Implementing care redesign activities

– i.e., care delivery enhancements such as reengineered care pathways using evidence-based medicine, standardized care pathways, and care coordination

• Reporting on Quality Measures• Using CEHRT in accordance with the BPCI Advanced

Model Participation Agreement• Attesting to a minimum of four MIPS Improvement Activities

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Learning System Activities

Participants will be required to take part in CMS Learning System Activities during the Model Years. It is not clear at this time what minimum participation requirements would entail.Learning System Activities may include, but are not limited to:• Learning sessions• Topic-specific webinars• Group-specific virtual collaborations• Semi-annual hypothetical “live case” visits between Participants• Regular site visits by CMS and CMS contractors to Participants,

Episode Initiators, and Participating Practitioners by request or at CMS’ discretion

• Showing interim results with structured qualitative inquiry• Hypothetical case studies for formal sharing based on site visits