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August 16, 2016

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AAOS Comments on CMS Proposed Rule for Physician Reimbursement

On July 25, 2016, the Department of Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS) released a new proposed rule which supplements the recent proposed Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) rule (read more in Advocacy Now online here). The proposed rule includes new cardiac care bundled payment models and incentives to increase cardiac rehabilitation usage, but also alters the Comprehensive Care for Joint Replacement (CJR) bundled payment model to remove hip fracture procedures and creates new pathways for CJR and additional models to qualify as Advanced Alternative Payment Models (APMs).

First, CMS noted AAOS concerns about the inclusion of hip fracture in the CJR model – AAOS has argued that the Medicare beneficiary population receiving care for hip fracture is significantly different from the patient population receiving elective hip and knee arthroplasty – and CMS thus proposed to create a new model specifically for these procedures. The so-called surgical hip/femur fracture treatment (SHFFT) model episodes would be initiated by Medicare Severity-Diagnosis Related Groups (MS-DRGs) 480-482 on discharge after hip and femur procedures, except major joint. The model will begin on July 1, 2017 and will continue for 5 performance years. Additionally, the SHFFT model is being tested in the same hospitals participating in the CJR model, so that all surgical treatment options for Medicare beneficiaries with hip fracture (hip arthroplasty and fixation) would be included in episode payment models. While AAOS lauds CMS for separating the SHFFT model from the CJR, AAOS is concerned that the SHFFT, akin to the CJR model, continues to be a hospital led bundle, is a mandatory program, and has a short implementation timeline. The AAOS will be providing comments on this proposed rule due to CMS within 60 days of formal publication in the Federal Register.

Second, CMS created a new Bundled Payments for Care Improvement (BPCI) voluntary model, set to start in calendar year 2018. According to CMS, this additional model builds on the BPCI initiative and furthers the Administration’s commitment “to create a health care system that provides better care, spends health care dollars more wisely, and makes people healthier.”

Finally, in addition to proposing new bundled payment models, CMS is proposing new pathways to allow the abovementioned new BPCI model, the existing CJR model, and the new SHFFT model to all qualify as Advanced APMs under MACRA. According to CMS, these bundled payment models could qualify as Advanced APMs beginning in 2018. The AAOS commends members of Congress and CMS leadership for acknowledging concerns about the exclusion of the CJR and BPCI models in the original proposed list of Advanced APMs. Extension of CJR, and potentially qualifying a new BPCI model, helps create greater patient access to even more effective and affordable specialty care.

“We’re encouraged by the inclusion of CJR and the new BPCI voluntary models into MACRA Advanced APMs,” says AAOS President Gerald R. Williams, Jr., MD.

“Patient care remains of the utmost importance to the AAOS and its members,” says Dr. Thomas C. Barber, chair of the AAOS Council on Advocacy. “Minimizing surgical complications and hospital readmissions, and speeding patient recovery are paramount. While the proposed policy changes released this week are improvements over the original proposed Quality Payment Program rules, we will keep working with CMS to ensure timely, high-quality, affordable specialty care delivery improvements for all Americans.”
 
For more information, visit www.aaos.org/macra or read the CMS fact sheet.