Mandatory Bundled Payment Models Are Back! 5 Things To Know

By: Tamara Cull, Senior Vice President, Aveus, a Division of Medecision

DATE: 12/13/2018

This guest blog is from Tamara Cull, Senior Vice President, Aveus. Aveus, a division of Medecision, sits at the intersection of strategy, customer experience, and innovation. Aveus specializes in helping complex organizations assess, implement and manage transformational business shifts.




My colleague, Kate Poglitsch at DataGen, posed a big question in her most recent blog “The Return of Mandatory Bundles: Good News?”, and I thought it was important to weigh in and say – this is GREAT news!

This is a signal from the current administration showing the acceptance of what those of us working in CMS bundled payment models since their inaugural launch in 2013 already knew.

These models work.

In her post, Kate made several predictions with which I agree. In addition to the DataGen predictions, I would add additional thoughts for your consideration:

#1: These will run concurrently with OCM

Given the way these models need to be operationalized, there is no other choice but to run them side by side and not force providers to pick one model over the other. This allows for the provision of holistic patient care, which CMS reports is a goal of this work. In addition, for the effectiveness and efficiency of staff and the outcomes for patients, it’s important not to have duplication of care management efforts. This happens if the models are not allowed to run in parallel.

#2: Episode length will be shorter

CMS has come out in favor of a 90-day episode of care and researchers found results in bundled payment models are achievable when the 90-day model is implemented. In addition, longer duration models are more complex to administer and require additional costs (staff/infrastructure) for provider teams to manage. CMS is highly sensitive to not overburdening physicians which is likely the source of this shorter duration model.

 #3: There will be similar issues as OCM

There is likely to be residual carry over of OCM model issues, no bundled payment model has achieved perfection, and CMS is committed to learning and evolving “real time.” There is a hope that teams have prioritized the need to address the big issues and, yes, attribution of episodes remains a battle CMS has not yet solved.

#4: Hospital outpatient providers will be included

The model is likely to dovetail nicely into other work a health system is already participating in which should make them welcome the opportunity to participate. They will see a benefit to their patients and outcomes with the ability to tap into quality improvement work and bring it to the outpatient setting. Additionally, outpatient provider teams already operate in an “out of the hospital walls” context – so moving toward a bundled payment care continuum model should be a natural progression for those teams.

#5: The model may not end up being mandatory

There are definite challenges moving directly into a mandatory model, but CMS has learned (the hard way) that voluntary participation in these models is not significant enough to change the way healthcare is delivered in this country. So, they had to answer the question, “do you launch a voluntary model with low participation (and therefore low research value) or launch a mandatory model that can actually test if this type model of care can be effective?”.

It’s no doubt CMS will have a hot debate around this issue, and the provider base – which they have protected – will have strong feelings about a mandatory model. So, look for mandatory to be the first thing to disappear if the heat gets too high.

There will be much more to come out of Washington in the coming days on this possible return of mandatory bundles and our teams will be following the news closely to evaluate how our experts can be prepared to help you succeed in these models.

Regardless if we see a mandatory or voluntary model launched, it is the continuation of this bundled payment work that is the exciting news!

Reach out to us to discuss further. You’re going to change. Why not make change rewarding? Contact me directly via email to talk about the changes your company faces today at


For more on what we know and don’t know about the new manadatory oncology program, visit DataGen’s oncology focused webpage.

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