CCS Announces Complimentary Bundled Payments Webinar; Reports CMS Program Delay

FOR IMMEDIATE RELEASE
Boston, Massachusetts, United States of America (Free-Press-Release.com) December 30, 2011 -- Concord, MA, December 30, 2011 – Comprehensive Care Solutions LLC (CCS) (www.ComprehensiveCareSolutions.com ) today announced that it will host a complimentary webinar on the CMS Bundled Payment for Care Improvement Program on Friday January 6, 2012 at 12:00 – 1:30 p.m. EST. You may register for this webinar by clicking on the following link: https://www3.gotomeeting.com/register/975929966.

On December 23rd, 2011 CMS announced a six-week delay in their Bundled Payment for Care Improvement data distribution and application filing timeline. While this could be viewed as a convenient extension of a very tight schedule, CCS views this as an acknowledgement by CMS of the enormous complexity of this program. CCS views this delay as an opportunity for organizations to better prepare for the very complicated task of designing an episode of care for the CMS application process as well as the even more complicated task of executing on this new risk based program if selected to participate. Below, we outline 5 tips on actions your organization can and should be taking now to take full advantage of the extended deadlines from CMS.

1. KNOW YOUR INTERNAL DATA
Organizations can do a lot to begin to build their understanding of an episode of care in their facilities and related entities by mining their own data, as well as publically available Medicare data.

Fran Cercek, MBA, Senior Financial Consultant for CCS, and an expert in hospital cost accounting systems, points out that “Most health care organizations have the information to build internal episodes of care based on discharge DRGs from their own systems data and should evaluate the performance within their own organizations across physicians and facilities. This type of analysis helps point to the DRGs which have the greatest variation in costs and outcomes, a key indicator of potential success under bundled payments.”

Rina Vertes, FSA, MAAA, Senior Actuarial Consultant for CCS and former Chief Actuary and Chief of Underwriting for BCBS of Massachusetts, says this analysis can be taken a step further by comparing the results of the internal analysis to regional and national benchmarks, particularly on the variation in rates of post-acute utilization. “We have seen geographic variation of as much as 30% difference in the total rate of post-acute care for certain DRGs. This type of variation for the very same diagnosis, based on location, not condition, could be an enormous opportunity under both Model 2 and Model 3 for organizations that understand and prepare a plan to address the variation.”
The Bottom Line – Internal data is available and could provide great insight, but needs to be organized and analyzed in order to provide value in understanding bundled payment opportunities. As is highlighted by our next must-do step, the time is now to undergo this internal analysis …
2. TAKE ADVANTAGE OF THE CMS LEARNING OPPORTUNITIES

CMS’s has announced a new Webinar Series that emphasizes the need for an organization to understand its internal data and the complexities in doing so. Their first Webinar on January 5, 2012 at 2 p.m. EST, “Episode Definition: What you need to know about the Bundled Payments for Care Improvement Initiative,” is “designed to assist organizations that have submitted Letters of Intent for Models 2-4 to jump start their application process by gaining an in depth understanding of the core elements that underlie BPCI episodes.” CCS will provide additional information on how to access these webinars in future releases.

The provision of these sessions is CMS’s way of helping organizations work through the complicated process of designing an episode of care and understanding the data available in order to increase organizations’ chances of success under this risk-based program. D. Bradley Wright, PhD, who is leading the CCS effort to analyze the CMS Claims Data, said “The data files CMS is constructing are enormous and very complicated, as witnessed by the recent delay in CMS’s production of sample files. It will be important to listen closely to what CMS is communicating in these webinars, as it will likely highlight the problems and potential solutions CMS is finding with the data analysis as they are producing the files.” Because keeping track of all of the CMS updates and education takes extensive time and resources, CCS maintains close contact with The Center for Medicare and Medicaid Innovations (CMMI) at CMS, and succinctly relays valuable and timely information to clients.
The Bottom Line – This is the first time CMS has tried to produce episode based data on this scale. Attending the webinars, understanding the messages being communicated, and incorporating CMS guidance into the planning work and final application product will be critical to success. CCS will continue to be the go-to source for clients to ask questions and obtain the most up-to-date CMS knowledge and news.

3. DO AN ORGANIZATIONAL READINESS ASSESSMENT

CCS has developed a Readiness Assessment Tool based on the CMS Bundled Payment for Care Improvement application. The CCS Readiness Assessment Tool helps organizations understand how their care delivery and other systems need to change to adapt to the new at risk environment. The Readiness Assessment Tool also helps organizations address these matters in the BPCI application and create a plan to implement the needed changes. “The application is extremely detailed and complicated.” says DeLyle Manwaring, MHA, Manager of CCS and lead on the application and readiness processes. “Organizations should understand what will be required to create a winning and competitive application now by creating a gap analysis to help guide your team’s efforts as you prepare for submission.”
The Bottom Line – Organizations need to understand where they stand in terms of preparedness for the actual application process. The CMS BPCI application is available and provides a great overview of the task ahead as organizations prepare for submission. The CCS Readiness Assessment Tool can help your organization gauge its readiness for this program and build a plan to complete the application and address gaps in readiness.
4. START ESTABLISHING THE STRUCTURES YOU WILL NEED FOR IMPLEMENTATION

The BPCI initiative is by its very nature designed to create new collaboration between various providers, particularly hospitals and physicians. However, the creation of these collaborative structures is not simple and not for the faint of heart. “While on one hand, CMS is pushing collaboration through model design and gain sharing, on the other hand, the government has indicated that they will be keenly focused on anti-competitive behavior and Stark and Anti-Kickback violations, including under the BPCI program. ” says Paul Jawin, JD, Partner and General Counsel for CCS. “We feel that while CMS is indicating some flexibility in their oversight of new models of collaboration between physicians and hospitals, other parts of the government have given mixed signals on how far they are willing to let these experiments go before they violate existing laws, which are not being modified for this effort. CCS is working with its bundled payment clients to design hospital/physician alignment structures, including gainsharing components, that are compliant while meetings the needs of the parties.”

The Bottom Line – Even if CMS and the other federal agencies were to give a green light for collaborating, designing, and executing on the legal structures necessary to support this type of collaboration, it takes time to design such structures and the process is never without complexity. Take the extra time now to map out a clear strategy, including with any potential partner organizations you may want to bring into the process, because you will need to execute quickly once the BPCI projects are approved and implemented.

5. PREPARE FOR CLINICAL TRANSFORMATION

The BPCI initiative is a risk-based payment reform, which means organizations must be ready to implement the changes they envision to bend the cost curve and beat their target application price immediately. In order to succeed under Bundled Payments, organizations will need to have identified and planned around specific opportunities for clinical improvement prior to the start date for BPCI. “Clinical transformation is challenging and requires clinical leadership and multi-stakeholder planning” says Donna Bright, PhD, CCS Senior Consultant in charge of helping clients prepare their clinical transformation implementation plans as part of the application process. “Organizations need to identify their clinical leaders and what those leaders are going to be doing on day one to drive and support the clinical changes necessary to achieve the Triple Aim of better health, better health care and reducing costs.”
The Bottom Line – On the first day of the BPCI contracts, organizations will be liable for the discounts they have agreed to provide to CMS. Organizations must be ready to implement their clinical transformation plans on or before the program goes into effect in order to capitalize on the financial opportunity that BPCI represents.

CONCLUSION

Yes, CMS has given us a mixed holiday blessing. While they have extended the deadline to complete the BPCI application, they are doing so because they have realized how complicated the task at hand will be both for themselves, as well as the organizations who will submit applications. CCS specializes in payment reform strategies and stands ready to help its clients and others navigate this process.

Please feel free to contact us to receive a copy of the CCS Whitepaper on Bundled Payments, and with any other questions, by visiting our website, www.ComprehensiveCareSolutions.com or by sending inquiries to info@ComprehensiveCareSolutions.com .

Bundled Payments     cms     Health Care Payment Reform