CMS Amendment Could Bring Welcome Changes to BPCI Advanced Participation Agreement

The Centers for Medicare & Medicaid Services (CMS) has issued an amendment to the Bundled Payments for Care Improvement (BPCI) Advanced Participation Agreement (Amendment). Changes imposed by the 18-page Amendment were largely based on stakeholder input and could streamline aspects of the program and ease burdens on both convener and non-convener participants. If CMS incorporates the Amendment into an Amended and Restated Participation Agreement[1], participants will have until October 1, 2019 (or other date if specified by CMS) to accept the terms of such agreement and extend the term of the agreement through 2022.

Participants that choose not to execute the Amendment will not receive any of the potential benefits of the Amendment, including the following notable changes:

  • Removal of 50% Payment Caps.
  • Addition of QPP List
  • Removal of Certain Reapplication Restrictions.
  • Adjustments to Secondary Repayment Source Requirements and Calculations.
  • Waiver of Originating Site Requirements for Telehealth.
  • Removal of References to Wholly-Owned Episode Initiators.


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