Nuts and Bolts of Implementing Bundled Payments

My last post described the design of a patient engagement pilot. A central (and most challenging) part of that pilot would be bundled payments. While designing the pilot for Utah last year, I worked out some of the nuts and bolts of implementing bundled payments, which was a crucial step in designing the pilot because, to this point, no private-sector bundled payment pilot has really truly completely gotten off the ground due to huge challenges with (1) defining the bundle of services included in the lump-sum payment and (2) amending contracts (i.e., figuring out how to dispense that payment to the various participating caregivers). So, if you happen to know someone working on bundled payments, this might be a good resource for them.

1. Defining the Bundle – Guiding Principles

We need a neutral steering committee to arbitrate any impasses. Decide on this at the first meeting where the bundle definition will be discussed.

We want to minimize exclusions, which will help providers have enough volume so they can wholeheartedly redesign care processes and spread redesign costs over a larger number of patients. Good stop-loss provisions will limit their risk. As described in the payer-hospital contracting section, including good stop-loss provisions will not have a net effect on the amount payers are reimbursing.

Minimizing exclusions will mean that the risk level of patients being cared for on a bundle will vary quite a bit. In order to avoid providers shunning those higher-risk patients, we need to create risk categories after we’ve defined the bundle. A patient’s risk category should be based on criteria that are easily available up front (before the surgery). When payers and providers set bundled prices, they will set a different bundled price for each risk category.

All participating in the bundle definition decision should be very familiar with the information in the payer-hospital contracting section.

A simpler bundle definition may not be as conceptually appealing, but it will allow the bundle definition to be completed faster so that momentum will not be lost. We can use the work already done by others and make minor adjustments (if necessary).

After the episode is selected, we need to collect all the bundle definitions out there and see where they are the same and where they differ so that the bundle definition decision can be narrowed down to a limited number of specific decisions.

A guiding principle in the bundle definition decision should be to include everything a patient would need to buy the “product.” The product of a knee replacement is to have the knee returned to full function. The product of a CABG is to have a heart fully perfused again and the patient is back to normal functioning.

Including post-acute care/rehab-type services in the bundle: Reasons to include it are (1) because the patient/insurer will know what the total price of the episode (i.e., product) is up front and (2) to encourage the reduction of avoidable services.

We probably shouldn’t include pre-procedure services because it just adds more administrative complexity than it’s worth.

When deciding on the standardized bundle, don’t forget to decide what day the 90-day window starts (on the day of discharge? on the day of the surgery?) and what to do with an in-bundle service that starts on the 89th day and continues past the end of the window (prorate it? cover the full cost of it?).

2 a) Amending Contracts Between Payers and Hospitals

This section has been prepared to simplify the process that payers and hospitals will go through to amend their contracts so that they can comply with the pilot requirement to prospectively determine prices for the standardized bundle.

To simplify the language in this guide, “hospital” is the term used to denote the primary contracting entity with a payer, although this party may be either a hospital or a healthcare system.

Instead of a contract amendment, payers and providers could opt for the less formal “partnering letter,” which defines the terms without needing to make any adjustments or amendments to existing contracts. Legal counsel can provide further clarification on this option.

Please see the hospital-caregiver contracting section for details on the process hospitals/healthcare systems and caregivers will go through to determine risk-sharing arrangements.

Step 1: Determine the bundled price

  • Using the payer’s claims history, do a retrospective reconstruction of each care episode (using the standardized bundle) that took place in the hospital over the last few years and trend those episode amounts forward to test-period prices
  • If different bundled prices will be set for different patient populations (e.g., male with BMI under 35, male with BMI over 35, female with BMI under 35, female with BMI over 35), organize those episodes into their appropriate groups and then average each group to get a test-period estimation of each group’s average price of a care episode
  • These averaged prices will be reduced in proportion to the net additional amounts the payer is expected to pay out for in-bundle services according to other provisions discussed in this guide (see Step 2 Option 2.2, Step 4, Step 5, Step 6, and Step 7) so that the average episode reimbursement level stays the same as it would be without this contract
  • Additionally, if any of the providers involved in providing care in an episode are already being reimbursed by the payer in a capitated manner, the bundled price will be reduced by the percent that historically has gone to that type of provider (this does not preclude capitated caregivers from participating in hospital-caregiver risk-sharing arrangements)

Step 2: Determine the reimbursement method

  • Option 2.1: Normal FFS with retrospective reconciliation
    • This is the simplest option, but it risks providers (hospitals and caregivers) having to pay money back to the payer if their up-front FFS reimbursements end up being more than what the retrospective reconciliation determines they should receive
    • The payer would take the role of performing the retrospective reconciliation—including using the hospital-caregiver risk-sharing agreements—to determine how much to reimburse/bill each participating provider
    • Aspects of the hospital-caregiver contracting section relating to avoiding back-billing can be ignored when hospitals and caregivers negotiate their risk-sharing arrangements
  • Option 2.2: Reduced FFS with retrospective reconciliation
    • Providers will continue to be reimbursed normally according to existing reimbursement processes, only reimbursement levels will be set to X% of normal reimbursement
    • Assumed as part of this option is that there would not be any back-billing; in other words, any reimbursement to a provider would not be required to be paid back even if that provider ended up being reimbursed more than what the retrospective reconciliation dictates and even if the payer’s total reimbursements for the care episode end up being more than the total bundled price
    • The payer would perform the retrospective reconciliation to determine how much additional money, if any, is owed to the provider group (according to the prospectively determined price), and then send that amount either to the hospital (which would make the hospital responsible for distributing that money according to hospital-caregiver risk-sharing agreements) or to the individual providers directly (which would make the payer responsible for performing the retrospective reconciliation, including taking into account hospital-caregiver risk-sharing arrangements)
    • Principles to guide the decision on where to set the reimbursement percentage:
      • No matter how high the reimbursement percentage is set, it does not affect providers’ upside risk as determined in the hospital-caregiver contracting section
      • A higher reimbursement percentage allows providers to receive more of their reimbursements earlier
      • If the reimbursement percentage is set high, it increases the likelihood of providers being overpaid if their costs for a bundle are higher than expected, which means the non-overpaid providers will be underpaid; in this situation, the reimbursement percentage acts as a cap on how much providers can be underpaid and instead causes the payer to pay out more than the bundled price, which, as described in Step 1, means the bundled price will be set lower to compensate for these additional expected outlays
      • The net effect on providers of a too-high reimbursement percentage is that it increases the downside risk of providers whose risk allocation is lower than 1 – Reimbursement Percentage and decreases the downside risk of providers whose risk allocation is higher than 1 – Reimbursement Percentage
      • Reimbursement percentages that seem to best balance all these factors are 80%, 85%, or 90%
    • Option 2.3: Lump sum paid to hospital up front
      • The hospital will be given the total bundled price as soon as an eligible episode is initiated
      • The hospital’s distribution of this lump-sum payment will be determined by hospital-caregiver negotiations
      • All providers would still need to submit claims to the payer for purposes of helping the hospital do a retrospective reconciliation to appropriately distribute the bundled payment with caregivers; these claims could either be submitted as no-pay claims or as regular claims and the payer would have to institute a regular review process to pull the ones that have already been paid for as part of the care episode
      • This option risks hospitals having to pay money back if the episode payment has to be reduced (see Step 4, Step 5, and Step 6); the payer performs a reconciliation for each episode (according to the decisions made in Step 3) to determine if any money is owed back to the payer
      • The hospital would be responsible for performing the reconciliation for the purpose of distributing the money according to hospital-caregiver risk-sharing agreements
    • Option 2.4: Monthly payments paid to hospital over course of episode
      • This is the same as Option 2.3 except the bundled price would be paid to the providers monthly over the course of the episode instead of as a single up-front payment
      • To determine what percent of the total bundled price should be paid each month, conduct an analysis of the historical percent of care episode costs incurred each month and break up the total bundled price over the episode window according to those percentages
      • Decide when monthly payments are due (e.g., on a certain day of the month, on the first day of each 30-day episode period, on the last day of each 30-day episode period)
      • This option has a lower risk of hospitals having to pay money back if the episode payment has to be reduced, but there is still some risk (see Step 4, Step 5, and Step 6) because the payer will perform a reconciliation for each episode (according to the decisions made in Step 3) to determine if any money is owed back
      • The hospital would be responsible for performing a retrospective reconciliation for the purpose of distributing the money according to hospital-caregiver risk-sharing agreements

Step 3: Decide on reconciliation timing

  • Decide how many months to wait after episode window has ended (to allow all episode-related claims to trickle in) before the episode will be considered eligible for reconciliation
  • Decide how frequently the payer should do reconciliations (e.g., monthly, quarterly, biannually)

Step 4: Set provisions for patients who change payers before the end of the episode

  • If doing Option 2.1 or Option 2.2, use that bundle’s Reduced Price (see below for how to calculate this) when doing reconciliation
  • If doing Option 2.3, need to get the appropriate amount back from the hospital (Appropriate Amount = Total PriceReduced Price)
  • If doing Option 2.4, the final episode payment will have to be pro-rated so that all payments for that episode add up to the Reduced Price
  • Calculating the Reduced Price:
    • First, need to determine the historical percentage of episode costs that accrue during each 30-day post-discharge period (these numbers will be known as % of Costs1-30, % of Costs31-60, and % of Costs61-90)
    • Next, need to determine the number of days the patient was no longer covered during each 30-day post-discharge period (these numbers will be known as # Not Covered1-30, # Not Covered31-60, and # Not Covered61-90)
    • Next, plug that information into the following formulas:

Reduced Price = Total Price x (1 – % Reduction)

% Reduction = (% of Costs1-30 x # Not Covered1-30 /  30)  + (% of Costs31-60 x  # Not Covered31-60 /  30)  + (% of Costs61-90  x # Not Covered61-90  / 30)

Step 5: Set leakage provisions (leakage = a patient receives in-bundle services from an outside provider during the episode window)

  • Option 5.1: Reduce the patient’s bundled price by X% of the total amount the payer had to reimburse outside providers for performing in-bundle services
  • Option 5.2: Each time the payer has to reimburse an outside provider for performing an in-bundle service, reduce that patient’s bundle price by the amount the inside provider would have been reimbursed for performing that same service (or, if the amount the payer had to reimburse the outside provider was less, then reduce that patient’s bundled price by that lesser amount instead)

Step 6: Determine complications penalties

  • If the bundle definition does not include all avoidable complications that could be attributed to services rendered as part of the care episode, a complication penalty should be implemented as an incentive for providers to work to reduce those avoidable complications
  • Determine the historical average cost to treat that complication and then use that number as a starting point to set the flat dollar amount penalty that will be used to reduce a patient’s bundled price if the patient experiences that complication
  • If the complication can only be partially attributed to services rendered as part of the care episode, that complication’s penalty should be reduced accordingly
  • This process can also be used if post-acute care is not included in the bundle definition and payers want to create an incentive for providers to minimize unnecessary referrals to post-acute care (or could instead offer a “non-referral bonus” instead of having it be a “referral penalty”), but need to make sure the pilot’s standardized quality metrics keep providers accountable for referring patients to post-acute care when indicated

Step 7: Determine stop-loss provisions to cap provider risk (not necessary if doing Option 2.2)

  • Option 7.1: An additional per diem amount for each day over X inpatient days will be added to any patient’s bundled price
  • Option 7.2: The payer will increase any patient’s bundled price by the amount of costs over X% of the original bundled price

Step 8: Decide on frequency of data sharing

  • Payers should regularly share claims data (e.g., monthly, quarterly, biannually) with providers to enable them to perform reconciliations and to help them track their episode utilization trends

2 b) Amending Contracts Between Hospitals and Caregivers

This document has been prepared to simplify the process that hospitals and caregivers will go through to create a risk-sharing arrangement for the bundled reimbursement they will be receiving from payers.

Instead of creating a contract, hospitals and caregivers could opt for the less formal “partnering letter,” which defines the terms without needing to make a formal contract. Legal counsel can provide further clarification on this option.

If any of the caregivers involved in providing in-bundle services are salaried by the hospital, please refer to Step 6 for instructions on how to adjust the processes described in Step 1 – Step 5.

If any of the caregivers involved in providing in-bundle services are reimbursed by the payer in a capitated manner, please refer to Step 7 for instructions on how to adjust the processes described in Step 1 – Step 5.

Please see the payer-hospital contracting section for details on the process payers and hospitals will go through to amend their contracts for bundled reimbursements.

Step 1: Decide which types of providers will bear risk

  • Make a list of all the provider types that will be needed to provide services included in the standardized bundle
  • For each provider type, determine if they will need to directly coordinate with the hospital and/or surgeon to reduce costs/improve quality
  • In the risk-sharing arrangement, include each provider type with which direct coordination is expected
  • For all other provider types, do not share the risk, but determine how they should be reimbursed
    • Option 1.1: Normal FFS
    • Option 1.2: Give a flat prospectively determined amount for each patient (and, if desired, can integrate provisions similar to those listed in the payer-hospital contracting section, such as stop-loss provisions)

Step 2: Determine the percent of the bundle that should be allocated to each provider type (this step is not necessary if the payer-hospital contract is using FFS or reduced FFS as the reimbursement method)

  • After subtracting out the amounts going to non-risk-sharing providers, determine the percent of the remaining amount that should go to each provider type according to historical average percentages

Step 3: Determine the withhold percentage and then do an initial allocation (this step is not necessary if the payer-hospital contract is using FFS or reduced FFS as the reimbursement method)

  • Before allocating anything to the risk-sharing providers, a percent of the bundle should be withheld until the retrospective reconciliation (described in Step 5) has been completed
  • Distribute the non-withheld portion of the bundle according to the percentages determined in Step 2
  • To avoid back-billing, each provider will be guaranteed to keep these initial allocations
  • The appropriate withhold percentage should balance the following factors:
    • A lower withhold percentage allows providers to receive more of their reimbursement sooner
    • Because providers will be guaranteed to keep their initial allocation, a lower withhold percentage also increases the frequency of providers being overpayed (especially considering the possibility of the bundle being reduced according to provisions in the payer-hospital contracting section), which means other providers will be underpaid more frequently, effectively increasing their risk to levels higher than arranged

Step 4: Decide what percent of the risk each provider will bear

  • Each at-risk provider must decide what percentage of the risk to bear
    • If the hospital decides to bear 70% of the risk and the total reimbursements for an episode add up to $1,000 less than the bundled price, the hospital will receive $700 of that excess; alternatively, if the total reimbursements for an episode add up to $1,000 more than the bundled price, $700 of that overage will come from the hospital (how this is done is explained in Step 5)
  • Option 4.1: Use the same percentages as the payment allocations from Step 2
  • Option 4.2: Use the percent of savings that would be attributable to the work of each provider type
    • If we think that 30% of the potential savings could be generated by surgeons’ efforts to lower costs, surgeons would bear 30% of the risk

Step 5: Agree to a process for performing retrospective reconciliations

  • If the hospital is required to perform retrospective reconciliations to allocate money according to hospital-caregiver risk-sharing arrangements, follow the same schedule as the one the payer uses for its reconciliations (see Step 3 of the payer-hospital contracting section)
  • Here is the recommended process for calculating the reconciliation payment that should be given to each risk-bearing provider (this process works the same regardless of the reimbursement method used by the payer-hospital contract):

Reconciliation Payment  = Total Deserved Reimbursement  – Amount Already Paid

Total Deserved Reimbursement  = Episode-related Claims  + Risk-sharing Amount

Risk-sharing Amount  = Risk %  x (Reduced Bundled Price  – Total of All Risk-sharing Providers’ Episode-related Claims)

Reduced Bundled Price  = Net Bundled Price Received from Payer  – Total Amount Already Paid to Non-risk-sharing Providers

Net Bundled Price Received from Payer   =   Total Bundled Price   +/-   Adjustments Made During Payer’s Reconciliation Process

  • If any reconciliation payment is calculated to be negative (meaning the provider was already paid more than the Total Deserved Amount), that provider will not be back-billed; instead, the following adjustment formula can be used to adjust the reconciliation payments for all the non-overpaid risk-bearing providers:

Adjusted Reconciliation Payment  = Reconciliation Payment  – Adjustment

Adjustment  = Adjusted Risk %  x Total Amount Overpaid to Risk-bearing Providers

Adjusted Risk %  = Risk %  / (100%  – Sum of Risk Percentages of Overpaid Providers)

  • In the event that a provider’s Adjusted Reconciliation Payment is calculated to be negative, repeat the adjustment formula after performing the following adjustments:
    • Set that provider’s Adjusted Reconciliation Payment to zero
    • Subtract that provider’s Reconciliation Payment from the Total Amount Overpaid to Risk-bearing Providers
    • Add that provider’s Risk % to the Sum of Risk Percentages of Overpaid Providers

Step 6: Changes to Step 1 – Step 5 for salaried caregivers

  • Step 1: If the salaried caregiver will not bear risk, no reimbursement changes are necessary—the caregiver will not be included in this contract
  • Step 2
    • If the payer-hospital contract is using FFS or reduced FFS as its reimbursement method: This step is not necessary
    • If the payer-hospital contract is using lump-sum payments paid up front or monthly as its reimbursement method: The bundle percentages allocated to salaried caregivers will be added to the employing hospital’s (for use in paying their salaries)
  • Step 3
    • If the payer-hospital contract is using FFS or reduced FFS as its reimbursement method: This step is not necessary
    • If the payer-hospital contract is using lump-sum payments paid up front or monthly as its reimbursement method: The hospital will contribute the appropriate amount of its allocated bundle percentage, which, as described in the changes to Step 2 above, includes its bundle percentage and the salaried caregiver’s bundle percentage
  • Step 4: No changes necessary; the salaried caregiver can still be allocated a risk percentage just like any other caregiver (refer to the changes to Step 5 below for an explanation of how this will work)
  • Step 5: Perform reconciliation calculations for salaried caregivers the same as for other caregivers except for the changes described below
    • The salaried caregiver’s Episode-related Claims and Amount Already Paid will be set to $0 and both will be added to the employing hospital’s amounts instead
    • In cases where the Total of All Risk-sharing Providers’ Episode-related Claims > Reduced Bundled Price, the salaried caregiver’s Risk % will be set to 0 and will instead be added to the employing hospital’s Risk %
    • The effect of these adjustments is to shift salaried caregivers’ downside risk to their employing hospitals but to preserve salaried caregivers’ upside risk so that they will share in the savings when they coordinate with other providers to lower costs

Step 7: Changes to Step 1 – Step 5 for caregivers that are reimbursed by the payer via capitation

  • Step 1: If the capitated caregiver will not bear risk, no reimbursement changes are necessary—the caregiver will not be included in this contract
  • Step 2
    • If the payer-hospital contract is using FFS or reduced FFS as its reimbursement method: This step is not necessary
    • If the payer-hospital contract is using lump-sum payments paid up front or monthly as its reimbursement method: The payer will subtract the bundle percentages allocated to capitated caregivers from the bundled price before giving it to the hospital (because the payer has already reimbursed the capitated caregiver for the services that will be rendered as part of the bundle)
  • Step 3
    • If the payer-hospital contract is using FFS or reduced FFS as its reimbursement method: This step is not necessary
    • If the payer-hospital contract is using lump-sum payments paid up front or monthly as its reimbursement method: Capitated caregivers will not be asked to contribute any of their capitated payments into the withhold, which means they will have no downside risk, but see the changes to Step 5 described below for an explanation of why an unequal upside/downside risk allocation for capitated caregivers is reasonable
  • Step 4: No changes necessary
  • Step 5: Perform reconciliation calculations for capitated caregivers the same as for other caregivers except that the capitated caregiver’s Amount Already Paid and Episode-related Costs should both be set to equal the amount the payer initially subtracted from the bundled price due to the caregiver being capitated
    • The effect of these adjustments is to make the bundle costs attributed to capitated caregivers always be the same, which means their direct costs will not place a financial burden on other providers by contributing to any overages; but, because upside risk will still be allocated to capitated caregivers, they will have an incentive to coordinate with other providers because they will get to share in the savings generated
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