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★ In a recent response to the proposed 2025 Inpatient Prospective Payment System (IPPS), ASA urged the Centers for Medicare & Medicaid Services (CMS) to expand opportunities for anesthesiologists to participate in alternative payment models (APMs). As leaders in perioperative care and care coordination, anesthesiologists would be essential to the successful implementation of CMS’s proposed Transforming Episode Accountability Model (TEAM). ASA opposes making alternative payment models mandatory and, if TEAM is finalized, our letter called for a voluntary, thoughtful roll out of the TEAM model over several years.
★ On April 10, 2024, the Centers for Medicare & Medicaid Services (CMS) posted the Hospital Inpatient Prospective Payment System (IPPS) proposed update for fiscal year 2025, along with proposed policy and regulation changes. The proposed rule would update Medicare payment policies and quality reporting programs relevant for inpatient hospital services, and build on key agency priorities, including advancing health equity and improving the safety and quality of care. Included in this rule is a mandatory 5-year alternative payment model (APM), called Transforming Episode Accountability Model (TEAM). The participants are acute care hospitals paid by IPPS. Downstream participants include the individual or entity that has entered into a written agreement with a TEAM participant pursuant to which the downstream participant engages in one or more TEAM activities. The five surgical procedures (inpatient & outpatient) include:
TEAM places the specialist as the principal provider near the anchor event with a hand off back to the primary care provider for longitudinal care management. You can access details at Transforming Episode Accountability Model (TEAM) | CMS.
★ To continue to encourage participation in Advanced APMs, Congress passed a minibus healthcare package on March 3, 2024,
that provides a 1.88% incentive payment for QPs for performance year 2024 (payment year 2026). Thus, the total additional financial incentive for participation in an Advanced APM in 2024 (beyond shared savings payments and any bonuses available in the model itself) is an approximately 2.63% increase to Medicare payments in 2026 (the 1.88% incentive payment plus the 0.75% CF update). The incentive payment is less than the previous levels of payments that Congress provided. Additionally, the payments could be less of a financial incentive than participation in MIPS.
★ The Centers for Medicare & Medicaid Services (CMS) posted
the Advanced Alternative Payment Model (APM) Incentive Payments for 2023 (PDF) on the Quality Payment Program (QPP) Resource Library. This resource provides information about the amount of Advanced APM incentive payments that were paid to eligible clinicians this year based on their participation in Qualifying APM Participant (QP) Performance Period 2021. Additional information about APM Incentive Payments is available on the Federal Register.
You can now log in to the QPP website using your HARP credentials (PDF) to see the amount your organization was paid for both the 10-digit National Provider Identifier (NPI) and the organization.
If you have not received your payment, you should check for your name on the 2023 QP Notice for APM Incentive Payment ZIP File (ZIP), which indicates that you will need to verify your Medicare billing information. If you do not verify your Medicare billing information by September 1, 2023, then CMS will not be able to issue your APM Incentive Payment. For instructions on how to verify your Medicare billing information, review the Zip File (ZIP) and Federal Register
As of 08/16/23, all organizations that applied for the 2-year extension of the BPCI Advanced Model have received a notification from CMS with the status of their application. For organizations whose applications have been accepted and are moving forward, CMS provided a unique 8-character Bundled Payments Identifier (BPID), which will start with the letter “A” and will be formatted as “AXXX-XXXX" with X representing numbers. Consult BPCI Advanced | CMS Innovation Center for pricing methodology, templates, webcasts, and other technical documents.
★ In October 2022, CMS announced a two-year extension of the BPCI Advanced Model. BPCI launched on October 1, 2018 and was set
to end on December 31, 2023. Now the program will end on December 31, 2025. There is a Request for Applications for Medicare-enrolled providers, suppliers, or Medicare Accountable Care Organizations (ACOs) to start participation in the Model on January 1, 2024 (Model Year 7). To be eligible for participation in the extension, New Convener Applicants must be Medicare-enrolled entities or Medicare ACOs. Existing Convener Participants that do not meet the new requirements will be permitted to remain in the Model during the extension years. To access the timeline, fact sheet, and other details, visit BPCI Advanced: Applicant Resources | CMS Innovation Center
★ The Center for Medicare & Medicaid Innovation (CMMI) has launched more than 50 alternative payment and care delivery model tests,
with 33 models now or still operational. Read the CMMI’s sixth report to Congress on its progress. During the period of this report more than 41,500,000 Medicare and Medicaid beneficiaries and individuals with private insurance in multi-payer model tests have been impacted by, have received care from, or will soon be receiving care furnished by the more than 314,000 health care providers and/or plans participating in the CMS Innovation Center payment and service delivery models and initiatives.
★ CMS Innovation Center (aka CMMI) released a report on a Strategic Refresh and indicated a new mandatory model
as part of the refresh to engage specialty care. Things of note in the report include:
★ Walmart and UnitedHealth officially announced their value-based care partnership
that begins next year with 15 sites in Florida and Georgia. The partnership of these two giant U.S. companies further increases value-based payment arrangements through Medicare Advantage plans. The arrangement will also expand virtual care services to 20 million of UnitedHealthcare’s commercial members. Read available details here.
★ 2022 APM Incentive Payment Details Available; Learn if Action Needed
The Centers for Medicare & Medicaid Services (CMS) has published 2022 Alternative Payment Model (APM) Incentive Payment details on the Quality Payment Program (QPP) website. To access this information, you can log in to the QPP website using your their HARP credentials. Eligible clinicians who were Qualifying APM Participants (QPs) based on their 2020 performance should have begun receiving their 2022 5% APM Incentive Payments earlier this summer. Review the 2022 Learning Resources for QP Status and APM Incentive Payment (ZIP) for details.
★ What Do I Need to Do in Order to Receive the APM Incentive Payment?
You will not need to do anything to receive your payment, unless CMS is unable to verify your Medicare billing information.
If you have not begun to receive your payment, you should check for your name in the 2022 QP Notice for APM Incentive Payment Zip File on the QPP Resource Library, which indicates that you will need to verify your Medicare billing information. If you do not verify your Medicare billing information by November 1, 2022, then CMS will not be able to issue your APM Incentive Payment. For instructions on how to verify your Medicare billing information, review the Zip File.
★ APM Incentive Payment Details Available on QPP Website
CMS has taken time to ensure correct payments and information are available during the 2022 payment year. CMS’s process includes verifying eligible clinicians’ Advanced APM participation and the calculation of the APM Incentive Payment. You can now log in to the QPP website to see the amount and the organization paid for both the 10-digit National Provider Identifier (NPI) and the organization.
★ Live or moving to California?
overview of Medicare ACOs in California from The SCAN Foundation.
★ Highlights from the AMA Annual Meeting:
Help private practices build their part in new payment models
Current Medicare payment system on an unsustainable path
Curated by: the ASA Payment and Practice Management Team
Date of last update: June 27, 2024