CMS Releases New Bundled Payment Program; Changes Made to CJR
On July 25, 2016, the Department of Health & Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS) proposed new models (Notice of Proposed Rulemaking for Bundled Payment Models for High-Quality, Coordinated Cardiac and Hip Fracture Care) that continue the Administration’s initiatives to shift Medicare payments from quantity to quality. Apart from introducing a new mandatory cardiac care bundle and cardiac rehabilitation incentive payments, this proposed rule provides an update to the existing mandatory joint replacement bundled payment model (i.e., the Comprehensive Care for Joint Replacement or CJR model), proposes a new voluntary model under the Bundled Payments for Care Improvement (BPCI) program, and creates a new pathway for physicians to qualify for increased payment incentives through the advanced Alternative Payment Models (A-APMs) under the proposed Quality Payment Program.
New hip fracture bundle. One of the proposed new episode payment models (EPMs) is the surgical hip/femur fracture treatment model (SHFFT). This bundle builds on the CJR model and CMS has proposed it as a hospital led bundle. The SHFFT model will begin on July 1, 2017 and will continue for 5 performance years. This model is being tested in the same hospitals participating in the CJR model (which means it could qualify as an A-APM), so that all surgical treatment options for Medicare beneficiaries with hip fracture (hip arthroplasty and fixation) would be included in episode payment models.
New pathway for eligibility as an advanced APM. CMS proposes to implement two different tracks within the EPMs whereby EPM participants that meet proposed requirements for use of CEHRT and financial risk would be in Track 1 (an A-APM track) and EPM participants that do not meet these requirements would be in Track 2 (a non-Advanced APM track). The Track 1 in each of the EPMs will:
- Require participants to bear risk for monetary losses that meets the proposed nominal risk criteria.
- Use quality measures that meet the proposed measure requirements to base payments.
- Require participants to report on the use of Certified Electronic Health Record Technology.
The CJR model which began this year could qualify as an A-APM beginning in 2018, and would include physicians who collaborate with hospitals participating in the models. In addition, the rule announced CMS’ intent to build upon the BPCI initiative with a new voluntary bundled payment model to begin in calendar year 2018 that would also potentially qualify under the proposed criteria for A-APMs.
The American Association of Orthopaedic Surgeons (AAOS) has stated that the Medicare beneficiary population receiving care for hip fracture is significantly different from the patient population receiving elective hip and knee arthroplasty and therefore lauds CMS’ acknowledgement of this difference. The AAOS is encouraged by the new BPCI voluntary model and the announced pathways for physicians to receive increased A-APM payments and the new gainsharing opportunities for physicians. However, AAOS is concerned that the SHFFT, akin to the CJR model, continues to be a hospital led bundle, is a mandatory EPM, and has a short implementation timeline. Further, AAOS would like to see more details on physician gainsharing guidelines as well as results of the existing BPCI models. The AAOS will be providing comments on this proposed rule due to CMS within 60 days of formal publication in the Federal Register.
CMS Fact sheet: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2016-Fact-sheets-items/2016-07-25.html