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 CMS Finalizes Rule, Delays Implementation of Three Mandatory EPMs

The Centers for Medicare & Medicaid Services (CMS) has finalized its rule pertaining to the agency’s cardiac care bundled payment program and changes to the existing Joint Replacement Model (CJR), delaying implementation to Jan. 1, 2018.
 
This marks the second implementation delay of the cardiac and joint replacement episode-based payment models (EPMs), after CMS on March 21, 2017, issued an interim final rule delaying the start date to Oct. 1, 2017.
 
The final rule, “Advancing Care Coordination Through Episode Payment Models (EPMs), Cardiac Rehabilitation Incentive Payment Model, and Changes to the Comprehensive Care for Joint Replacement Model (CJRs),” comes after a comment period that started on March 21, 2017, in which CMS solicited feedback on delaying the rule past Oct. 1, 2017.
 
Several organizations provided comments, including the American Health Care Association (AHCA), which says long term/post-acute care (LT/PAC) providers should be aware that hospitals will be incentivized to partner with skilled nursing centers.
 
“Under the model, hospitals are mandatorily held accountable for cost and quality outcomes for patients receiving an acute myocardial infarction [AMI], coronary artery bypass graft [CABG], or orthopedic surgical hip/femur fracture treatment [SHFFT] procedure,” says James Michel, senior director, Medicare research and reimbursement, at AHCA.
 
“Hospitals will be responsible for all Medicare Part A and B spending on care delivered in 90-day episodes, including post-acute care, and will be incentivized to partner with SNFs to achieve efficiency and quality,” he says.
 
It its April 19, 2017, comment letter addressed to CMS Administrator Seema Verma, AHCA said it appreciated the proposed three-month delay and suggested the agency “make significant modifications to the model, including reducing its size, scope, and mandatory nature.” AHCA also emphasized its recommendations about the original proposed rule, made in October 2016. This includes:
 
·         Modify how providers are eligible to use the SNF three-day rule waiver;
·         Evaluate ongoing demonstrations and achieve conclusive results before expanding those same policies to additional demonstration programs;
·         Adopt policies that encourage hospitals to be more inclusive of post-acute care providers in care redesign and share in savings with them, rather than treating them like a commodity that must be managed; and
·         Implement better policies to allow providers to more reliably identify patients who fall in and out of episodes.
 
According to AHCA, CMS responded by acknowledging that it may consider those comments in any future rulemaking on EPMs.
 
The two new cardiac EPMs, the AMI EPM and the CABG EPM, will be implemented in 98 selected markets across the country. The orthopedic SHFFT EPM will be added in the 67 markets currently participating in the CJR demonstration.
 
The final rule can be viewed in the Federal Register.
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