For the second time under the Trump administration, CMS has delayed the implementation date of bundled payments for cardiac care and an expansion of a joint replacement model, which are now due to begin Jan. 1, 2018, opening the door to additional changes, like making the models voluntary rather than mandatory.
The agency had previously pushed back the start of the Advancing Care Coordination Through Episode Payment Models (EPMs) and Cardiac Rehabilitation Incentive (CRI) Payment Model from July 1, 2017 to Oct. 1, 2017. The EPMs would include bundled payment models for acute MI and coronary artery bypass graft (CABG) covering around 1,120 acute care hospitals in 98 geographic areas, while the CRI model would run in 45 geographic areas. The same interim final rule also pushed back the expansion of the Comprehensive Care for Joint Replacement (CJR) model.
At the time of the initial delay, CMS said it would allow for modifications to the policy and better understanding from participants, as well as align the first payment year for the EPMs with a full model year, rather than a 6-month period from July 1 to Dec. 31, 2017. According to the published rule, healthcare organizations agreed extra time was needed.
“Commenters requested at least six months of preparation time after the EPM 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,” the agency said.
CMS noted some commenters went beyond discussing the start date and suggested changes to the model’s design, including data, pricing, quality measures, coding and notification requirements. CMS said all of those concerns are outside the scope of the delay, and wouldn’t be addressing them in this final rule.
However, the agency said it would consider those comments for future rulemaking, and modifications to the models would now be easier to achieve with the later start date. CMS noted multiple commenters asked for participation to be voluntary, not mandatory, a position advocated by HHS Secretary Tom Price, MD, and CMS Administrator Seema Verma in the past and supported by groups like the Federation of American Hospitals and Presbyterian Health Services of New Mexico.
For the time being, the American College of Cardiology (ACC) appears satisfied with the delayed start date and some extra time to discuss additional changes.
"Creating value-based payment models for patients with cardiovascular disease is extremely challenging and the ACC has urged (CMS) to proceed with great caution in implementing and testing these models in order to ensure that they allow for accurate beneficiary attribution, valid quality and cost measurement, meaningful comparisons, and ultimately development of best practices to achieve better health outcomes for patients,” ACC President Mary Norine Walsh, MD, said in a statement to HealthExec. “This newest delay provides an opportunity to continue working with CMS to find ways to further refine and improve the effectiveness of the models' clinical and operational designs. In the meantime, the College encourages members who are part of the model to continue to prepare for implementation.”