HCC Best Practice Advisory (BPA) Alerts a Hot Topic in Compliant Condition Capture

By Jason Jobes, SVP, Norwood Solutions

HOT TOPIC QUESTION: Are you using Epic HCC BPAs (or similar tools) and are you worried about their appropriateness or compliance?

DISCLOSURE: Norwood does not possess/sell any technology that competes with use of the Epic BPA or currently partner with organizations that have similar functionality. This question is aimed at regulatory compliance only.

I am anxious to know how you use Epic BPAs (or other EHR/tools) functionality. Thanks for reading, and as always, your comments, likes, and sharing of posts helps drive dialogue on hot topics across our industry. Thank you for engaging.

Recently I have been having some great discussions with leaders across the industry around their use of Epic’s HCC (hierarchical condition category) BPA (best practice advisory) alert. These alerts are intended to let a provider know if a patient has a risk eligible condition that is yet to be addressed (billed on a claim) during the calendar year. 

For example, if it is June and I present to my primary care provider and no one has addressed my congestive heart failure, during the visit the BPA will alert the clinician to that condition not being addressed in hope that they will. At hand is the looming question: Should you be alerting providers about these gaps and if so, how and when is it appropriate?

The intention of the BPA is twofold. Conceptually it is aimed at helping drive population health. For example, if I have a chronic condition that none of my providers have addressed this year I am more likely to have an acute episode. More practically it is used to ensure that my condition is addressed and my risk score is accurate (assuming I do have the condition).

The decision points are endless on how the BPA is built. Some of those decisions include:

• Which providers see the BPA? Do you show it only for primary care or for specialists?
• If specialists see the BPA then which conditions present to them? Do they see only conditions in their specialty or all risk-eligible conditions?
• What types of visits does the BPA show up to the provider? Does it prompt in all office visits or just for particular visit types like an annual wellness visit?
• Does the BPA act as a passive alert or is there a close visit validation that forces the provider to take action before closing the encounter?
• Does the BPA only include items that risk adjust on the patient’s problem list or are other conditions included (i.e., past claims or suspect conditions)?

These are just some of the endless considerations for organizations using Epic that are focused on accurate capture of patient complexity.

Recently I have had some health debate on if BPAs are appropriate and compliant. What are your thoughts? I have yet to see any guidance on the topic from CMS, the U.S. Department of Health and Human Services (HHS), the HHS Office of Inspector General (OIG), or the Department of Justice (DOJ). 

So I conclude by asking you: Are these alerts OK in your estimation, and if so how do you use them?  Please send me an email at jason@norwood.com. 

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