The American Hospital Association (AHA) has asked CMS to delay the March 12 deadline for hospitals to apply for the Bundled Payments for Care Improvement Advanced program and to furnish more detailed information on how the program would work.
In a letter to CMS Administrator Seema Verma, AHA Executive Vice President Thomas P. Nickels wrote that while the AHA agrees with the principles underlying the program and believes it could help transform care delivery, it is concerned that CMS has not provided sufficient details about the model, which makes it difficult for hospitals and clinicians to make informed decisions about participating in the voluntary program.
He recommended that CMS delay the deadline for applications from March 12 to April 16 and provide a “complete package of detailed programmatic information by March 1.”
The new program includes 29 inpatient clinical episodes and three outpatient clinical episodes. The episode of care begins at the start of an inpatient or the start of an outpatient procedure and ends 90 days later. Participants will receive regular Medicare fee-for-service payments for care.
The program will evaluate providers’ performance retrospectively every six months, comparing the total cost of care for the clinical episode to a target price that will be provided before the performance period begins. Payment for participants also is tied to performance on quality measures. CMS will use the performance and quality data to determine whether the provider will receive a bonus or is required to repay CMS for part of the reimbursement.
“Our members support the healthcare system moving toward the provision of more accountable, coordinated care and are redesigning delivery systems to increase value and better serve patients,” Nickels wrote.
In the eight-page letter, Nickels requested that CMS make changes in the program he says would facilitate hospital participation in the program and success in providing quality care to patients and saving costs. He asked the agency to clarify which quality measures would be applied to which clinical episodes and voiced concerns about the hospitalwide readmission measure CMS plans to use as a quality measure.
Among other suggestions was a request that CMS add a sociodemographic adjustment to the readmission, complication, and mortality measure, adding that research has demonstrated that community factors beyond the hospital’s control affect patient outcomes after discharge.
“A sociodemographic adjustment using a well-established proxy for community factors — such as income or dual eligibility for Medicare and Medicaid — would help level the playing field among providers caring for large numbers of disadvantaged patients and those who do not do so,” Nickels wrote.