CMS Delays New Bundled Payments Model

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In late-February, we reported that CMS had recently finalized new Innovation Center models. However, now, in an interim rule, CMS is delaying the implementation of the mandatory cardiac bundle program and cardiac rehabilitation program from July 1 to Oct. 1.

The rule also postpones the expansion of the mandatory joint replacement bundle program to include other treatments for hip and femur fractures in addition to hip replacement from July 1 to Oct 1. Further delays the effective date of a final rule to implement the joint replacement bundle initiative, the cardiac rehabilitation incentive payment model and the initiative to advance care coordination through episode payment models from March 21 to May 20. CMS is seeking comment on a potential further delay of the programs to January 1, 2018.

Original announcement

As we wrote, in the original announcement from CMS on the proposed program, the agency finalized three significant new policies related to: (1) cardiac care; three new payment models will support clinicians in providing care to patients who receive treatment for heart attacks, heart surgery to bypass blocked coronary arteries, or cardiac rehabilitation following a heart attack or heart surgery; (2) orthopedic care; one payment model to support clinicians in providing care to patients who receive surgery after a hip fracture, other than hip replacement; and (3) CMS finalized updates to the Comprehensive Care for Joint Replacement Model, which began in April 2016.

CMS comments regarding new delay

CMS writes that the delays allow it more time to review the programs. They also state it gives providers time to prepare for the changes in payment under the models. The agency is accepting comments on the delays for 30 days starting on March 21. CMS stressed that it would prefer to line the payment period with the calendar year as well.

Stakeholder response

As reported by the Advisory Board, stakeholders said the decision raises important questions about how President Trump and his HHS will approach value-based care and mandatory (as opposed to voluntary) payment bundles. They cite Ashish Jha, a professor of health policy at the Harvard School of Public Health, who said the delays might suggest CMS will make the programs voluntary, which he said would affect the pool of participants and ultimately drive up costs.

In contrast, Carolyn Magill—CEO of Remedy Partners, a firm that helps hospitals and health systems with bundled payment programs—said, “We have found that voluntary models provide a forum for more engaged participation.”

This comes after groups like the American Hospital Association had criticized the payment models for being “too much, too soon.” The Federal of American Hospitals praised the decision to delay the bundles.

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