- CMS recently delayed the launch date of three mandatory Medicare cardiac and orthopedic bundled payment models and the Cardiac Rehabilitation Incentive Payment program from May 20, 2017, to Jan. 1, 2018.
The final ruling from the federal agency will impact the Episode Payment Models, which target 90-day care episodes for acute myocardial infarctions, coronary artery bypass grafts, and surgical hip and femur fracture treatments.
Modifications to the Medicare Comprehensive Joint Replacement (CJR) model will also move from July 1, 2017, to the start of 2018.
CMS originally introduced the cardiac and orthopedic bundled payment models, cardiac rehabilitation incentive payment model, and CJR modifications in December 2016.
The federal agency scheduled the mandatory cardiac and orthopedic programs to start in 2017 to allow providers to participate in them for MACRA. The three models qualify as Advanced Alternative Payment Models, which come with a 5 percent Medicare incentive payment based on sufficient participation.
The CJR model changes would also qualify the bundled payment model an Advanced Alternative Payment Model in 2018.
However, CMS pushed back the original implementation dates in January 2017 and March 2017. The first delay stemmed from the Trump administration’s temporary freeze on federal regulations at the start of his presidential term.
The federal agency then delayed the start dates by another three months in March 2017 to give providers and the agency more time to review and prepare for the initiatives.
The most recent delay will be the third for the compulsory bundled payment models and incentive payment program.
Some healthcare industry groups and stakeholders voiced their support for the federal agency’s decision to launch the programs in 2018.
CMS stated that a number of commenters on the rule “requested at least six months of preparation time after the EPM [Episode Payment Models] final rule takes effect, stating that the EPM episodes are complex, involve sick patients with many entry points into acute care settings, and require the establishment of networks for coordination across numerous specialists.”
In addition, they also told CMS that the later launch date would expand the first performance year to include “meaningful performance outcomes.”
The original delay would leave providers with just a three-month performance period. Since the models encompass a hospitalization and another 90 days after discharge, the shorter period would not generate enough episodes to accurately reflect provider performance on care quality and healthcare costs.
The American Hospital Association also recently backed the implementation delay until 2018, but warned CMS that additional delays “would effectively turn the start date for these programs into a moving target.”
Other commenters also expressed concerns that the bundled payment model delay would hinder Advanced Alternative Payment Model participation.
The Quality Payment Program track only includes a limited number of approved models that qualify for the 5 percent incentive payment. For 2017, CMS selected seven models but aimed to expand that number to boost Advanced Alternative Payment Model participation.
However, the recent delay will prevent some eligible clinicians from becoming qualifying participants for the maximum incentive payment under MACRA in 2017.
Additionally, CMS pointed out that many stakeholders commented on the mandatory nature of the Medicare incentive payment and bundled payments models.
Some stakeholders, such as Premier Healthcare Alliance, argued that compulsory Medicare bundled payment models overstepped legislative authority and forced some providers to enter inappropriate value-based reimbursement arrangements.
The National Association of ACOs (NAACOS) also critiqued mandatory bundled payment models because they oftentimes clash with accountable care organizations. The industry group called on CMS to indefinitely suspend the models until the federal agency resolved financial conflicts with ACO models.
Although some stakeholders have backed keeping the bundled payment models mandatory. Five healthcare policy experts from the Brookings Institution recently claimed that “making these models optional would eliminate the ability to generate robust evidence on their effectiveness, dealing a severe blow to efforts to use bundled payments to improve care delivery in orthopedics and cardiac care, and to the chances for bringing bundled payments to scale nationally in the coming years.”
Despite the recent debate, CMS stated that changing the nature of the bundled payment models is out of this rulemaking’s scope. But it will consider the changes in future rulemaking.