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What to Know Ahead of the BPCI-A Deadline

Analysis  |  By Jack O'Brien  
   September 19, 2020

Participating providers have received claims data through June, which offers a decent understanding of the financial performance of organizations through the peak of the pandemic.

Providers in a federally qualified alternative payment model have important decisions to make ahead of an upcoming deadline.

Participants in the Bundled Payments for Care Improvement Advanced (BPCI-A) have less than a week to submit one of three amendments to remain in the program.

The model, supported by the Centers for Medicare & Medicaid Services (CMS) and the Center for Medicare and Medicaid Innovation (CMMI), aims to "support healthcare providers who invest in practice innovation and care redesign to better coordinate care and reduce expenditures."

Related: Healthcare Financial Trends to Follow in the COVID-19 Era

Keely Macmillan, senior vice president of policy and solutions management at Archway Health, a Boston-based payment solutions company, spoke with HealthLeaders about the three amendment options that healthcare leaders must choose from.

Amendment 1:

  • Participating providers can elect to waive upside and downside risk for all episodes that are in 2020.
  • Normally, there is upside and downside risk, according to Macmillan, but Medicare has waived that requirement because of the COVID-19 pandemic.
  • "[Option one] means you wouldn't earn any bonus and you wouldn't have to repay any penalty," Macmillan said.

Related: Forward-looking Financial Processes for a Post-pandemic Landscape

Amendment 2:

  • Participating providers stay in upside and downside risk, but CMS removes any patient who had a COVID-19 positive diagnosis from the reconciliation.
  • The amendment also allows providers to exclude patients who have COVID-19 for a longer period than the first amendment.
  • Macmillan said that providers wouldn't be held at risk for patients who had been diagnosed with COVID during the 90-day episode but would still be at risk for all of the other episodes that were triggered during the year. 

Related: 4 Coronavirus Financial Considerations for Health System Leaders

Amendment 3:

  • Do nothing.
  • Don't sign either amendment and continue to stay upside and downside risk for all of the patient population this year.
  • Macmillan said the risk applies to Model Year 3, meaning episodes that triggered on or after January 2020.

Participating providers have received claims data through June, according to Macmillan, which offers a decent understanding of the financial performance of organizations through the peak of the pandemic.

Looking ahead at the decision-making process, Macmillan said that healthcare finance leaders will have to account for variance in both COVID-positive cases and geography.

Macmillan added that even organizations that didn't treat many COVID-positive patients should still consider a potential drop off in volumes due to the slow return of elective surgeries and procedures.

"Even if you are doing well and there are a few bundles you have left, or you don't have a high prevalence of COVID among the patients who triggered episodes, it may still be too risky to stay in two-sided risk if you have such a small volume leftover in the program and not enough volume to spread risk across a normal population of patients," Macmillan said.

Jack O'Brien is the Content Team Lead and Finance Editor at HealthLeaders, an HCPro brand.


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