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Bundled Payments for Care Improvement
    Application Guidance Webinar




                    April 19, 2012
Bundled Payments for Care Improvement


                      Speakers
Sheila Hanley, MPH, MA, Rachel Homer, Elyse Pegler, MPH

       Bundled Payments for Care Improvement
              Patient Care Models Group
      Center for Medicare & Medicaid Innovation




                                                          2
Thank You


Thank you for your interest in partnering
with the Innovation Center and CMS to
help redesign care, improve quality and
reduce costs across our country.




                                            3
Webinar Purpose


• Provide further guidance on what
  information should be included in strong
  BPCI applications
   – We have posted the Application Guidance document
     on our website:
     http://innovations.cms.gov/initiatives/Bundled-
     Payments/index.html
   – We are discussing key portions of that document on
     this webinar




                                                          4
Agenda


I. Review Applicant Roles (as discussed in 3/8/12 webinar)
II. Discuss key sections of Application Guidance Document
      • Guidance for Facilitator Conveners
      • Section B: Model Design – Care Improvement and
          Gainsharing
      • Section B: Model Design – Provider Engagement
      • Section B and Section C: Episode Definition and Table C1
      • Section D: Quality of Care and Patient Centeredness
III. Upcoming Webinars and Key Dates




                                                                   5
Agenda


I. Review Applicant Roles (as discussed in 3/8/12 webinar)
II. Discuss key sections of Application Guidance Document
      • Guidance for Facilitator Conveners
      • Section B: Model Design – Care Improvement and
          Gainsharing
      • Section B: Model Design – Provider Engagement
      • Section B and Section C: Episode Definition and Table C1
      • Section D: Quality of Care and Patient Centeredness
III. Upcoming Webinars and Key Dates




                                                                   6
Types of Applicants


• As a BPCI applicant, you must apply as one
  of the following types of applicants:
   – Awardee
   – Awardee Convener
   – Facilitator Convener
       • Applying with Designated Awardees /
         Designated Awardee Conveners




                                               7
Illustrating the Applicant Roles




                                   8
Agenda


I. Review Applicant Roles (as discussed in 3/8/12 webinar)
II. Discuss key sections of Application Guidance Document
      • Guidance for Facilitator Conveners
      • Section B: Model Design – Care Improvement and
          Gainsharing
      • Section B: Model Design – Provider Engagement
      • Section B and Section C: Episode Definition and Table C1
      • Section D: Quality of Care and Patient Centeredness
III. Upcoming Webinars and Key Dates




                                                                   9
Facilitator Conveners:
   Deviations from Overall Approach

• A significant deviation is defined as:
   – Use of a fundamentally different approach or
      intervention
   – Absence of a core element of the facilitator convener’s
      over-arching response
   – Use of the over-arching approach to a fundamentally
      different population
   – Difference in implementation timing that would impact
      the timing of results
   – Other major differences the applicant believes merit
      discussion




                                                               10
Facilitator Conveners:
          When Describing Deviations


• When there are significant deviations for some Designated
  Awardees/Designated Awardee Conveners, the Facilitator
  Convener should:
   – Present a strong rationale for this variation
   – Discuss how any operational/implementation challenges
     will be addressed
   – Indicate to which/how many Designated
     Awardees/Designated Awardee Conveners these variations
     apply




                                                              11
Agenda


I. Review Applicant Roles (as discussed in 3/8/12 webinar)
II. Discuss key sections of Application Guidance Document
      • Guidance for Facilitator Conveners
      • Section B: Model Design – Care Improvement and
          Gainsharing
      • Section B: Model Design – Provider Engagement
      • Section B and Section C: Episode Definition and Table C1
      • Section D: Quality of Care and Patient Centeredness
III. Upcoming Webinars and Key Dates




                                                                   12
Care Improvement


• BPCI Goal: promote better care at lower costs by
  using episode-based care to support care redesign
• Applicants should clearly articulate their
  comprehensive care improvement plan here
• Other questions in the application ask applicants to
  build on the responses in this section




                                                         13
Gainsharing & Care Improvement


• Applicants in this initiative may propose to use
  gainsharing as a tool to align incentives to redesign
  care
   – Redesigned care, leading to better outcomes for
     beneficiaries, is the end goal
• Because gainsharing is a tool to support care
  redesign, gainsharing payments must be tied to
  actual changes in behavior and/or increases in
  quality




                                                          14
Speaking a Common Language

• Applicants are expected to partner with other entities to
  redesign care. These partners fall into two categories:
• Bundled Payment Participating Organizations (BPPOs)
   – Episode initiating BPPOs: For awardee conveners or
     designated awardee conveners only
• Bundled Payment Participating Practitioners (BPPPs)




                                                              15
Speaking a Common Language (Cont’d)


• Gainsharing: distribution of gains accrued due to internal
  organizational cost savings during the episode of care, as well as
  distribution of gains received via episode reconciliation
  payment(s)
• Gainsharing arrangement contracts: contracts among the
  entities who will share gains
• Enrolled BPPOs and Enrolled BPPPs: The subset of BPPOs and
  BPPPs who are participating in gainsharing arrangements and
  are parties to gainsharing arrangement contracts are referred to
  as Enrolled BPPOs and Enrolled BPPPs




                                                                       16
Highlighting Three Key Application Questions


     Section B: Model Design – Gainsharing

•   Methodology, capacity, contractual relationships and
    Model 4
•   Gainsharing in support of care improvement, oversight
•   Process and requirements for becoming an Enrolled BPPO
    or Enrolled BPPP




                                                             17
(a) Question B13 in the Awardee application, B14 in the Awardee
Convener application, and B15 in the Facilitator Convener application:


 In response to this question, applicants should address the following:
          1. Methodology for allocating gains
          2. Capacity to track internal costs, quality performance, and
             changes in care that can be attributed to actions taken by
             BPPOs and/or BPPPs (e.g., HIT capabilities, information sharing
             between and among awardee, BPPOs, and BPPPs)
          3. Contractual relationships
              a. Who are signatories to gainsharing arrangement
                 contracts?
              b. Are BPPPs employed (salaried) or independent? Does this
                 change the signatories of the gainsharing arrangement
                 contracts?




                                                                               18
Model 4 Gainsharing Methodology


• Any physician payment in Model 4 that would be
  higher than the Medicare Physician Fee Schedule
  payment that would otherwise apply, whether that
  be a hospital’s base rate for physician services or the
  base rate plus incentive payments, is considered
  gainsharing




                                                            19
(b) Question B14 in the Awardee application, B15 in the Awardee
Convener application, and B16 in the Facilitator Convener application:



  In response to this question, applicants should address the
        following:
       1. What care redesign interventions are gainsharing
            payments associated with?
      2. What entities are overseeing gainsharing
         arrangements? (e.g., what entities make decisions
         on who may become an Enrolled BPPO or BPPP, and
         what entities make decisions on which Enrolled
         BPPOs and BPPPs have met gainsharing
         requirements and therefore receive gainsharing
         incentive payments?)


                                                                         20
(c) Question B15 in the Awardee application, B16 in the Awardee
Convener application, and B17 in the Facilitator Convener application



In response to this question, applicants should address the
     following:
1. The process, including quality and other criteria, to
     become an Enrolled BPPO or BPPP
2. The gainsharing requirements, including quality
     criteria, for an Enrolled BPPO or BPPP to receive a
     gainsharing incentive payment




                                                                        21
Agenda


I. Review Applicant Roles (as discussed in 3/8/12 webinar)
II. Discuss key sections of Application Guidance Document
      • Guidance for Facilitator Conveners
      • Section B: Model Design – Care Improvement and
          Gainsharing
      • Section B: Model Design – Provider Engagement
      • Section B and Section C: Episode Definition and Table C1
      • Section D: Quality of Care and Patient Centeredness
III. Upcoming Webinars and Key Dates




                                                                   22
Why CMS is asking about BPPP Engagement?


• Letters from BPPPs are an opportunity to demonstrate
  physician/practitioner buy-in
• CMS is seeking applications that present strong evidence of
  physician commitment to align incentives through bundled
  payments




                                                                23
Specifications for BPPP Letters of Agreement


• No required format for these letters
• Applicants may create form letters
• No minimum number of required letters
• Applicants may seek letters from BPPP representatives (e.g.,
  Chief Medical Officer)
• For BPPPs who are or will be Enrolled BPPPs (participating in
  gainsharing):
   – These are not binding gainsharing contracts; BPPPs may
     opt-in or opt-out later
   – Letters do not need to detail terms of gainsharing
     arrangements


                                                                  24
Agenda


I. Review Applicant Roles (as discussed in 3/8/12 webinar)
II. Discuss key sections of Application Guidance Document
      • Guidance for Facilitator Conveners
      • Section B: Model Design – Care Improvement and
          Gainsharing
      • Section B: Model Design – Provider Engagement
      • Section B and Section C: Episode Definition and Table C1
      • Section D: Quality of Care and Patient Centeredness
III. Upcoming Webinars and Key Dates




                                                                   25
Episode Definitions


• In Models 2-4, in all clinical conditions, we are
  seeking broad episode definitions

• We are seeking model designs that lend
  themselves to rapid scaling; therefore, CMS
  may request changes from applicants to
  promote commonalities among awardees




                                                      26
Excluded Services


• In Models 2, 3 & 4 applicants may propose excluded
  readmissions to acute inpatient hospitals by MS-DRG

• In Models 2 & 3, applicants may propose excluded non-IPPS
  Part A and Part B services during the post-discharge period
  by principal ICD-9 diagnosis code (e.g. Excluded SNF services,
  excluded outpatient services)

• In Model 4, all Part A and B services during an included
  (related) readmission are included; all Part A and B services
  during an excluded (unrelated) readmission are excluded




                                                                   27
Model 2, 3 & 4 Awardee Conveners
             Section B: Model Definitions & Table C1

•   Episode Parameters:
     – Anchor MS-DRGs
     – Length of episode
     – Proposed exclusions
     – Rate of discount

• Model 2 & 4 Awardee Conveners: the episode parameters may not
  vary by episode-initiating BPPO; the target price will vary by episode-
  initiating BPPO

• Model 3 Awardee Conveners only: The episode parameters & the
  target price will be set at the Awardee Convener level . These may not
  vary by episode-initiating BPPO



                                                                            28
Model 2, 3 & 4 Facilitator Conveners
             Section B: Model Definitions & Table C1

•   Episode Parameters:
     – Anchor MS-DRGs
     – Length of episode
     – Proposed exclusions
     – Rate of discount

• Model 2 & 4 Facilitator Conveners: Facilitator Conveners define the
  episode parameters
   – Designated Awardees/Designated Awardee Conveners may choose
      which episodes to participate in
   – The episode parameters may not vary by Designated
      Awardee/Designated Awardee Convener; the target price will vary
      by Designated Awardee/Designated Awardee Convener


                                                                        29
Agenda


I. Review Applicant Roles (as discussed in 3/8/12 webinar)
II. Discuss key sections of Application Guidance Document
      • Guidance for Facilitator Conveners
      • Section B: Model Design – Care Improvement and
          Gainsharing
      • Section B: Model Design – Provider Engagement
      • Section B and Section C: Episode Definition and Table C1
      • Section D: Quality of Care and Patient Centeredness
III. Upcoming Webinars and Key Dates




                                                                   30
Quality Metrics


• Applicants must propose to CMS the set of quality metrics we
  should use to measure quality in this initiative

• CMS will synthesize these proposed metrics into a consistent
  set to be used across many awardees

• These quality metrics are distinct from gainsharing-specific
  quality metrics, which Enrolled BPPOs and BPPPs must meet to
  receive gainsharing payments




                                                                 31
Required Minimum Quality Standards


• Awardees, and their BPPOs and BPPPs must
  maintain or improve their aggregate performance
  on:
   – Hospital Inpatient Quality Reporting System measures
   – Hospital Outpatient Quality Data Reporting Program
     measures
   – Physician Quality Reporting System measures




                                                            32
Agenda


I. Review Applicant Roles (as discussed in 3/8/12 webinar)
II. Discuss key sections of Application Guidance Document
      • Guidance for Facilitator Conveners
      • Section B: Model Design – Care Improvement and
          Gainsharing
      • Section B: Model Design – Provider Engagement
      • Section B and Section C: Episode Definition and Table C1
      • Section D: Quality of Care and Patient Centeredness
III. Upcoming Webinars and Key Dates




                                                                   33
Conclusion


Thank you for the work you are doing to redesign
  care.

The Innovation Center looks forward to receiving
  your applications and testing your approaches to
  redesigning care.




                                                     34
Key Dates


• The online application portal will be available the week of
  April 23, 2012
   – Coming Soon: Technical Assistance Webinar on how to access and
     use the BPCI Online Application Portal
• The applications or Models 2-4 are now due June 28, 2012
  by 5 PM EST




                                                                      35
Resources and Further Questions


• Please see the following resources on our website:
  http://innovations.cms.gov/initiatives/Bundled-Payments/
   – Application Guidance Document
   – Non-fillable PDF applications
   – Technical clarifications document for non-fillable PDF
     applications
   – Frequently Asked Questions

     If you have further questions that have not yet been addressed, please
     email us: BundledPayments@cms.hhs.gov




                                                                              36

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Webinar: Bundled Payments - Application Guidance for Models 2-4

  • 1. Bundled Payments for Care Improvement Application Guidance Webinar April 19, 2012
  • 2. Bundled Payments for Care Improvement Speakers Sheila Hanley, MPH, MA, Rachel Homer, Elyse Pegler, MPH Bundled Payments for Care Improvement Patient Care Models Group Center for Medicare & Medicaid Innovation 2
  • 3. Thank You Thank you for your interest in partnering with the Innovation Center and CMS to help redesign care, improve quality and reduce costs across our country. 3
  • 4. Webinar Purpose • Provide further guidance on what information should be included in strong BPCI applications – We have posted the Application Guidance document on our website: http://innovations.cms.gov/initiatives/Bundled- Payments/index.html – We are discussing key portions of that document on this webinar 4
  • 5. Agenda I. Review Applicant Roles (as discussed in 3/8/12 webinar) II. Discuss key sections of Application Guidance Document • Guidance for Facilitator Conveners • Section B: Model Design – Care Improvement and Gainsharing • Section B: Model Design – Provider Engagement • Section B and Section C: Episode Definition and Table C1 • Section D: Quality of Care and Patient Centeredness III. Upcoming Webinars and Key Dates 5
  • 6. Agenda I. Review Applicant Roles (as discussed in 3/8/12 webinar) II. Discuss key sections of Application Guidance Document • Guidance for Facilitator Conveners • Section B: Model Design – Care Improvement and Gainsharing • Section B: Model Design – Provider Engagement • Section B and Section C: Episode Definition and Table C1 • Section D: Quality of Care and Patient Centeredness III. Upcoming Webinars and Key Dates 6
  • 7. Types of Applicants • As a BPCI applicant, you must apply as one of the following types of applicants: – Awardee – Awardee Convener – Facilitator Convener • Applying with Designated Awardees / Designated Awardee Conveners 7
  • 9. Agenda I. Review Applicant Roles (as discussed in 3/8/12 webinar) II. Discuss key sections of Application Guidance Document • Guidance for Facilitator Conveners • Section B: Model Design – Care Improvement and Gainsharing • Section B: Model Design – Provider Engagement • Section B and Section C: Episode Definition and Table C1 • Section D: Quality of Care and Patient Centeredness III. Upcoming Webinars and Key Dates 9
  • 10. Facilitator Conveners: Deviations from Overall Approach • A significant deviation is defined as: – Use of a fundamentally different approach or intervention – Absence of a core element of the facilitator convener’s over-arching response – Use of the over-arching approach to a fundamentally different population – Difference in implementation timing that would impact the timing of results – Other major differences the applicant believes merit discussion 10
  • 11. Facilitator Conveners: When Describing Deviations • When there are significant deviations for some Designated Awardees/Designated Awardee Conveners, the Facilitator Convener should: – Present a strong rationale for this variation – Discuss how any operational/implementation challenges will be addressed – Indicate to which/how many Designated Awardees/Designated Awardee Conveners these variations apply 11
  • 12. Agenda I. Review Applicant Roles (as discussed in 3/8/12 webinar) II. Discuss key sections of Application Guidance Document • Guidance for Facilitator Conveners • Section B: Model Design – Care Improvement and Gainsharing • Section B: Model Design – Provider Engagement • Section B and Section C: Episode Definition and Table C1 • Section D: Quality of Care and Patient Centeredness III. Upcoming Webinars and Key Dates 12
  • 13. Care Improvement • BPCI Goal: promote better care at lower costs by using episode-based care to support care redesign • Applicants should clearly articulate their comprehensive care improvement plan here • Other questions in the application ask applicants to build on the responses in this section 13
  • 14. Gainsharing & Care Improvement • Applicants in this initiative may propose to use gainsharing as a tool to align incentives to redesign care – Redesigned care, leading to better outcomes for beneficiaries, is the end goal • Because gainsharing is a tool to support care redesign, gainsharing payments must be tied to actual changes in behavior and/or increases in quality 14
  • 15. Speaking a Common Language • Applicants are expected to partner with other entities to redesign care. These partners fall into two categories: • Bundled Payment Participating Organizations (BPPOs) – Episode initiating BPPOs: For awardee conveners or designated awardee conveners only • Bundled Payment Participating Practitioners (BPPPs) 15
  • 16. Speaking a Common Language (Cont’d) • Gainsharing: distribution of gains accrued due to internal organizational cost savings during the episode of care, as well as distribution of gains received via episode reconciliation payment(s) • Gainsharing arrangement contracts: contracts among the entities who will share gains • Enrolled BPPOs and Enrolled BPPPs: The subset of BPPOs and BPPPs who are participating in gainsharing arrangements and are parties to gainsharing arrangement contracts are referred to as Enrolled BPPOs and Enrolled BPPPs 16
  • 17. Highlighting Three Key Application Questions Section B: Model Design – Gainsharing • Methodology, capacity, contractual relationships and Model 4 • Gainsharing in support of care improvement, oversight • Process and requirements for becoming an Enrolled BPPO or Enrolled BPPP 17
  • 18. (a) Question B13 in the Awardee application, B14 in the Awardee Convener application, and B15 in the Facilitator Convener application: In response to this question, applicants should address the following: 1. Methodology for allocating gains 2. Capacity to track internal costs, quality performance, and changes in care that can be attributed to actions taken by BPPOs and/or BPPPs (e.g., HIT capabilities, information sharing between and among awardee, BPPOs, and BPPPs) 3. Contractual relationships a. Who are signatories to gainsharing arrangement contracts? b. Are BPPPs employed (salaried) or independent? Does this change the signatories of the gainsharing arrangement contracts? 18
  • 19. Model 4 Gainsharing Methodology • Any physician payment in Model 4 that would be higher than the Medicare Physician Fee Schedule payment that would otherwise apply, whether that be a hospital’s base rate for physician services or the base rate plus incentive payments, is considered gainsharing 19
  • 20. (b) Question B14 in the Awardee application, B15 in the Awardee Convener application, and B16 in the Facilitator Convener application: In response to this question, applicants should address the following: 1. What care redesign interventions are gainsharing payments associated with? 2. What entities are overseeing gainsharing arrangements? (e.g., what entities make decisions on who may become an Enrolled BPPO or BPPP, and what entities make decisions on which Enrolled BPPOs and BPPPs have met gainsharing requirements and therefore receive gainsharing incentive payments?) 20
  • 21. (c) Question B15 in the Awardee application, B16 in the Awardee Convener application, and B17 in the Facilitator Convener application In response to this question, applicants should address the following: 1. The process, including quality and other criteria, to become an Enrolled BPPO or BPPP 2. The gainsharing requirements, including quality criteria, for an Enrolled BPPO or BPPP to receive a gainsharing incentive payment 21
  • 22. Agenda I. Review Applicant Roles (as discussed in 3/8/12 webinar) II. Discuss key sections of Application Guidance Document • Guidance for Facilitator Conveners • Section B: Model Design – Care Improvement and Gainsharing • Section B: Model Design – Provider Engagement • Section B and Section C: Episode Definition and Table C1 • Section D: Quality of Care and Patient Centeredness III. Upcoming Webinars and Key Dates 22
  • 23. Why CMS is asking about BPPP Engagement? • Letters from BPPPs are an opportunity to demonstrate physician/practitioner buy-in • CMS is seeking applications that present strong evidence of physician commitment to align incentives through bundled payments 23
  • 24. Specifications for BPPP Letters of Agreement • No required format for these letters • Applicants may create form letters • No minimum number of required letters • Applicants may seek letters from BPPP representatives (e.g., Chief Medical Officer) • For BPPPs who are or will be Enrolled BPPPs (participating in gainsharing): – These are not binding gainsharing contracts; BPPPs may opt-in or opt-out later – Letters do not need to detail terms of gainsharing arrangements 24
  • 25. Agenda I. Review Applicant Roles (as discussed in 3/8/12 webinar) II. Discuss key sections of Application Guidance Document • Guidance for Facilitator Conveners • Section B: Model Design – Care Improvement and Gainsharing • Section B: Model Design – Provider Engagement • Section B and Section C: Episode Definition and Table C1 • Section D: Quality of Care and Patient Centeredness III. Upcoming Webinars and Key Dates 25
  • 26. Episode Definitions • In Models 2-4, in all clinical conditions, we are seeking broad episode definitions • We are seeking model designs that lend themselves to rapid scaling; therefore, CMS may request changes from applicants to promote commonalities among awardees 26
  • 27. Excluded Services • In Models 2, 3 & 4 applicants may propose excluded readmissions to acute inpatient hospitals by MS-DRG • In Models 2 & 3, applicants may propose excluded non-IPPS Part A and Part B services during the post-discharge period by principal ICD-9 diagnosis code (e.g. Excluded SNF services, excluded outpatient services) • In Model 4, all Part A and B services during an included (related) readmission are included; all Part A and B services during an excluded (unrelated) readmission are excluded 27
  • 28. Model 2, 3 & 4 Awardee Conveners Section B: Model Definitions & Table C1 • Episode Parameters: – Anchor MS-DRGs – Length of episode – Proposed exclusions – Rate of discount • Model 2 & 4 Awardee Conveners: the episode parameters may not vary by episode-initiating BPPO; the target price will vary by episode- initiating BPPO • Model 3 Awardee Conveners only: The episode parameters & the target price will be set at the Awardee Convener level . These may not vary by episode-initiating BPPO 28
  • 29. Model 2, 3 & 4 Facilitator Conveners Section B: Model Definitions & Table C1 • Episode Parameters: – Anchor MS-DRGs – Length of episode – Proposed exclusions – Rate of discount • Model 2 & 4 Facilitator Conveners: Facilitator Conveners define the episode parameters – Designated Awardees/Designated Awardee Conveners may choose which episodes to participate in – The episode parameters may not vary by Designated Awardee/Designated Awardee Convener; the target price will vary by Designated Awardee/Designated Awardee Convener 29
  • 30. Agenda I. Review Applicant Roles (as discussed in 3/8/12 webinar) II. Discuss key sections of Application Guidance Document • Guidance for Facilitator Conveners • Section B: Model Design – Care Improvement and Gainsharing • Section B: Model Design – Provider Engagement • Section B and Section C: Episode Definition and Table C1 • Section D: Quality of Care and Patient Centeredness III. Upcoming Webinars and Key Dates 30
  • 31. Quality Metrics • Applicants must propose to CMS the set of quality metrics we should use to measure quality in this initiative • CMS will synthesize these proposed metrics into a consistent set to be used across many awardees • These quality metrics are distinct from gainsharing-specific quality metrics, which Enrolled BPPOs and BPPPs must meet to receive gainsharing payments 31
  • 32. Required Minimum Quality Standards • Awardees, and their BPPOs and BPPPs must maintain or improve their aggregate performance on: – Hospital Inpatient Quality Reporting System measures – Hospital Outpatient Quality Data Reporting Program measures – Physician Quality Reporting System measures 32
  • 33. Agenda I. Review Applicant Roles (as discussed in 3/8/12 webinar) II. Discuss key sections of Application Guidance Document • Guidance for Facilitator Conveners • Section B: Model Design – Care Improvement and Gainsharing • Section B: Model Design – Provider Engagement • Section B and Section C: Episode Definition and Table C1 • Section D: Quality of Care and Patient Centeredness III. Upcoming Webinars and Key Dates 33
  • 34. Conclusion Thank you for the work you are doing to redesign care. The Innovation Center looks forward to receiving your applications and testing your approaches to redesigning care. 34
  • 35. Key Dates • The online application portal will be available the week of April 23, 2012 – Coming Soon: Technical Assistance Webinar on how to access and use the BPCI Online Application Portal • The applications or Models 2-4 are now due June 28, 2012 by 5 PM EST 35
  • 36. Resources and Further Questions • Please see the following resources on our website: http://innovations.cms.gov/initiatives/Bundled-Payments/ – Application Guidance Document – Non-fillable PDF applications – Technical clarifications document for non-fillable PDF applications – Frequently Asked Questions If you have further questions that have not yet been addressed, please email us: BundledPayments@cms.hhs.gov 36