In a letter to the agency, the AHA really useful the CMS make accessible extra data by March 1 after which delay the application deadline from March 12 to April 16.
The CMS did not reply to a request for touch upon the AHA’s suggestions.
The CMS introduced the Bundled Payments for Care Improvement-Advanced Model in January, and mentioned the primary cohort for the model would start Oct. 1 and run via Dec. 31, 2023.
In the letter, Thomas Nickels, AHA’s government vice chairman of presidency relations and public coverage, mentioned whereas the AHA supported the BPCI-Advanced Model, extra data on this system design is required so its members could make “well-informed decisions.”
The letter particularly known as on the CMS to give clinicians extra data on the methodology used to change goal costs below the model. While the CMS supplied goal value specs for years 1 and a pair of of the model, goal costs for future model years weren’t supplied, the AHA mentioned.
Additionally, the CMS indicated that it’s going to regulate goal costs semi-annually. The AHA urged the company “to provide a detailed methodology for how it will re-base target prices and to ensure that any re-basing methodologies do not progressively lower target prices at an unachievable rate,” Nickels mentioned.
The AHA additionally requested extra particulars about how high quality measures will probably be scored below the model, particularly how the measures will probably be adjusted and benchmarked.
Clarification on which which high quality measures will probably be utilized to every medical episode was requested as nicely. The BPCI-Advanced Model contains 32 clinical-care episodes that suppliers can select from, 29 of that are within the inpatient setting and three within the outpatient setting.
The AHA mentioned it was involved that a few of the proposed high quality measures are “poorly aligned with the care episodes and patient populations.” For instance, the letter factors out that the superior care plan measure is required for all medical episodes, however can technically solely be utilized to physicians teams as a result of it hasn’t been endorsed by the National Quality Forum for hospital use.
The AHA criticized some facets of the BPCI-Advanced Model within the letter just like the inclusion of the hospital-wide readmission measure.
“If the CMS is intent on using the hospital-wide readmission measure in the BPCI Advanced model, we strongly urge the agency to re-test the measure for reliability and validity when applied to just those patients in the care episode,” Nickels wrote.
Similar to many stakeholders, the AHA supported the truth that the BPCI-Advanced Model will probably be thought-about an advanced-alternative cost model below MACRA though the AHA was “disappointed” that the model is not thought-about a MIPS-APM, which makes reporting standards simpler for docs.