The Task Force strongly encourages CMMI to convene a special committee of industry experts to examine and to refine the trending methodology. Unpredictability of final prices because the trend can change the price up to 14% from the time a bundle starts until reconciliation.Failure to address the impact of catastrophic episodes on trend rates, both in the baseline and performance periods, and.Inconsistency in trend rates among DRGs in a bundle which can and has resulted in DRGs with complications sometimes having a lower trended price than DRGs without complications,.Failure to address the problems of low volume DRGs both with regard to the trend rates and the Winsorization thresholds,.Failure to limit changes in the Winsorization thresholds from quarter to quarter,.Failure to directly account for changes in unit prices that occur at the beginning of each fiscal year,.The trending method has many key flaws including, but not limited to: Pricing calculations should be designed to limit, not increase, the uncertainty of bundled payments. Using the full data set results in the most accurate baseline prices and reduces price uncertainty. Precedence rules should be eliminated from the baseline pricing calculations.Baseline prices should be locked-in for three years, as presently designed.Transparency will engender trust and lead to systemic improvements in pricing methodology. Calculations and algorithms for determining prices should be transparent.The date range for claims used to calculate baseline prices should be fixed and never subject to change once CMS delivers target prices to participants. Lock -in the set of claims used to determine prices.Price stability is very achievable and the Task Force recommends four important principles to improve the stability in the establishment of baseline prices: The BPCI program has experienced dramatic swings in target prices. We believe a primary requirement for successfully moving markets towards value-based competition is the existence of price stability. The Task Force is deeply committed to achieving the triple aim through our participation in the BPCI Initiative and other programs underway as a result of the passage of the Affordable Care Act.īased on the current concerns as it relates to our experience with the first reconciliation, we propose policy solutions that we believe would be well received by participants as well as operationally feasible for CMMI.ĭetails describing the proposal are outlined below, categorized by core operating policies. We sincerely appreciate the Center for Medicare and Medicaid Innovations’ (CMMI) responsiveness to date to participant feedback about the BPCI Initiative. Our outputs will not reflect the simple self-interest of any one organization or market segment, but rather agreement on common private and public approaches that will best facilitate transformation. The Task Force’s shared principles reflect our commitment to a specific timeline for the migration from fee-for-service toward payment models that promote patient-centered care and improved population health. We hope to provide a critical mass of policy, operational and technical support from the private sector that, when combined with the work being done by CMS and other public and private stakeholders, can increase the momentum of delivery system transformation. Representing a diverse set of organizations from various segments of the industry – currently including providers, health plans, employers, consumers and academic institutions – we share a common commitment to transform our respective business and clinical models to deliver the triple aim of better health, better care and reduced costs. The Health Care Transformation Task Force (previously known as the Health System Transformation Task Force) is pleased to provide input on CMS’ recent announcement of methodological changes to the Bundled Payments for Care Improvement (BPCI) initiative.Īs we described in previous communications, the Health Care Transformation Task Force (Task Force) is an emerging group of private sector stakeholders that is coming together to accelerate the pace of delivery system transformation. In Bundled Payments, Policy Communications
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