Some stakeholders may apply to become a “Participant”, which is an entity that falls under the BPCI Advanced Model Agreement with CMS. CMS requires all participants to take a downward financial risk from the outset (i.e. agree to pay the refund amount if the actual costs of the service exceed the target prices) and classify them into two categories: agree and non-agree participants. Both categories of participants may establish relationships with downstream physicians and health care practitioners to share the payment of net compensation or to allocate responsibility for reimbursement amounts, as appropriate. However, there are differences between organizers and nonwovens, for which we provide below a high-level summary. Convener participants must bear the full financial risk to the CMS on behalf of at least one acute hospital or medical practice and enter into an agreement with a physician group practice or acute hospital requiring the medical practice or hospital to comply with the terms of the BPCI Advanced Model Agreement. CMS also classifies doctors` offices and acute hospitals participating in BPCI Advanced as “downstream episode initiators” responsible for triggering the clinical episode for which the participant is ultimately financially responsible. Public schools offering an SNS apply the TRA as a reduction to the annual SNS participation fee. Following the TRA`s request, families who join the SRS receive an invoice with the balance to be paid. When CMS indicated that the one-year waiting period would indeed apply to participants who wished to participate with different downstream episode initiators15, many Convener participants immediately objected. CMS, for its part, indicated, before the expiry of a deadline of 1 March 2019, that the waiting time would not prevent participants agreeing to apply for Model Year 3, which would make it possible to terminate participants agree – several of whom have concluded advanced BPCI agreements with CMS – (whether retroactive to 1 March, or prospective for other denunciations), some or any such agreement without fear of being excluded from the notification period of Model Year 3. With this change, the one-year waiting period is now formally abolished. However, the amendment now allows downstream episode initiators to recover CMS`s explicit right to collect a reimbursement arrears by reducing payments independent of Medicare.
Provided that all contractual downstream episode initiation agreements contain such provisions, CMS has mitigated the secondary source of reimbursement requirements imposed on the participants concerned. Assuming that the same change is included in the BPCI Advanced Agreement in Model 3, participation in the programme could be attractive as a participant or not for organisations with more limited financial resources.. . . .