Hospitals interested in applying for the BPCI Advanced program should note that there are several options for their participation. However, participants will be limited only to options for which they submit applications by March 12, 2018. Therefore, to keep their options open hospitals must submit applications for any alternative structure that they later may wish to adopt.
The alternatives for hospitals are:
Participation as an episode initiator: The hospital assumes financial risk for all episodes that are initiated at its facility.
Participation as a convener: The hospital assumes financial risk for a group of providers who contract with the hospital. These may be hospitals or physician groups who act as episode initiators (EIs), and are probably affiliated with the hospital.
Participation as an EI with a non-provider convener: The hospital contracts with a separate entity and becomes an episode initiator for that entity. The convener assumes financial risk for all episodes and may share the financial results with the EI according to individual contracts.
In all cases the entity in blue assumes the financial risk and reward. The entities in white are episode initiators.
Under certain circumstances, the hospital serving as the convener for independent physician group practices (PGPs) may facilitate those practices becoming qualified participants (QPs) under MACRA, which allows them to receive an additional payment for their Part B payments.
While the final decision on the organization structure need not be made now, participants will be limited to the structures for which they submit applications that are due on March 12, 2018. Therefore, the hospital should submit applications now for any structure they may wish to consider before signing final contract in August. Failure to do so will limit them to the structures for which they submitted applications.
In addition to submitting the application, all applicants all applicants should also submit a data request to receive both the summary data and the historical claims data for all episodes. This will allow them to evaluate their opportunities and risks under this program.