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CMS Modifies Medicare Shared Savings Program Overlap Policy for BPCI Advanced Model

For CFO, Strategic Planning Executives

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As referenced in a recently updated FAQ, the Centers for Medicare & Medicaid Services (CMS) has been considering how to address model overlap between Bundled Payments for Care Improvement Advanced (BPCI Advanced) and the Medicare Shared Savings Program (MSSP) for Model Year 3, beginning Jan. 1, 2020. In an email last week to BPCI Advanced participants, CMS announced that, for Model Year 3 reconciliation calculations, BPCI Advanced will no longer exclude MSSP beneficiaries.

Specifically, CMS will include expenditures for items and services furnished to beneficiaries assigned to MSSP tracks 1, 1+, 2, BASIC track (levels A thru E), and ENHANCED track. For participants with clinical episodes that span between model years 2 and 3, CMS will apply the BPCI Advanced Model Year 1 and 2 MSSP overlap policy to clinical episodes with a date of discharge from the anchor stay or completion of the anchor procedure on or prior to Dec. 31, 2019. Clinical episodes that have a date of discharge from the anchor stay or completion of the anchor procedure on or after Jan. 1, 2020, will fall under the BPCI Advanced Model Year 3 MSSP overlap policy.