Prior to the amendment, cms would impose a one-year waiting period before that participant could reapply to participate in BPCI Advanced if, for whatever reason, a participant decided to terminate the BPCI Advanced agreement prematurely. However, it was not clear whether the one-year waiting period for „replication“ is to ask a participant for the summonses to apply with a completely different group of downstream episode initiators. The amendment further expanded the opportunities for participants to spread financial risks among their downstream episode initiators and eliminated some administrative burdens associated with cmS refund collection. The initial BPCI Advanced agreement made participants directly liable for repayment amounts and imposed incriminating requirements to ensure that participants had adequate access to capital on their behalf and to their downstream episode initiators for the duration of the agreement. New applicants have until June 24, 2019 to apply. Current BPCI Advanced participants have had until June 1, 2019 to make an optional amendment to the original BPCI Advanced agreement, recently published by CMS. The Centers for Medicare – Medicaid Services (CMS) has issued an amendment to the Advanced Participation Agreement (BPCI) Advanced Participation Agreement (Amendment). The amendments made by the 18-part amendment were largely based on stakeholder input and streamlined aspects of the program and eased the burden on convening participants and non-organizers. If CMS includes the amendment in a revised and revised participation agreement, participants have until October 1, 2019 (or any other date, if the CMS indicates) to accept the terms of this agreement and extend the duration of the agreement until 2022.
In addition to the changes reflected in the application for Model Year 3, CMS offered current participants the opportunity to amend their existing BPCI Advanced model agreements. The recently released amendment – which would be effective in execution (and will likely be automatically included in model agreements for new year 3 participants) contains the following changes: some stakeholders may apply to become a „participant,“ an entity that concludes the BPCI Advanced model agreement with CMS. CMS requires all participants to take a financial risk from the outset (i.e. to pay the amount of the refund when the actual expenses per service exceed the target prices) and categorizes them into two categories: participants and non-organizers. Both categories of participants may establish relationships with downstream physicians and non-medical physicians to share net payment compensation or, if necessary, to apportion responsibility for reimbursement amounts. However, there are differences between those who are not summoned and those who are not summoned, for whom we provide a high-level synthetic summary below. When cms indicated that the one-year wait would effectively apply to participants wishing to participate with different downstream episode initiators, 15 participants quickly objected. CMS issued guidelines again before March 1, 2019, deadline of the single „retroactive payment directive“ that the waiting period would not prohibit conveners from applying for Model Year 3, which would not require convening participants, many of whom have several ADVANCED BPCI agreements with CMS, to terminate the latter (retroactively until March 1). , or forward-looking for other terminations) some or all of these agreements without fear of being excluded from the type 3 registration year. The amendment now formally removes the one-year waiting period. September 2019: CMS distributes participation agreements for Model Year 3 to selected candidates.
November 2019: Selected candidates sign and present participation contracts in addition to their profile.