The AAMC Oct. 12 submitted a comment letter to the Centers of Medicare and Medicaid Services (CMS) regarding the cancellation of Episode Payment Models (EPMs) under the proposed rule entitled, “Medicare Program; Cancellation of Advancing Care Coordination through Episode Payment and Cardiac Rehabilitation Incentive Payment Models; Changes to Comprehensive Care for Joint Replacement Payment Model (CJR)”. The rule proposes to: 1) eliminate the Episode Payment Models (EPMs) and Cardiac Rehabilitation (CR) incentive payment model, and 2) reduce the number of metropolitan statistical areas (MSAs) required to participate in CJR.
Episode Payment Models (EPMs)
The EPMs were designed to incentivize providers to deliver higher quality cardiac and orthopedic care at a lower cost. The EPMs were designed around three clinical conditions:
- Acute Myocardial Infarction (AMI) Model,
- Coronary Artery Bypass Graft (CABG) Model,
- Surgical Hip and Femur Fracture Treatment (SHFFT) Model.
Prior to the release of CMS’ proposed rule to cancel EPMs, EPMs were scheduled to launch on January 1, 2018, and end December 31, 2021. Participation in EPMs was mandatory for hospitals located in select Metropolitan Statistical Areas (MSAs). The AMI and CABG Models were originally mandated in 98 MSAs comprising approximately 1,120 hospitals. The SHFFT model would be implemented in the 67 CJR MSAs, including approximately 860 hospitals.
Comprehensive Care for Joint Replacement Payment Model(CJR)
CMS proposes to reduce the number of metropolitan statistical areas, or MSAs, required to participate in CJR from 67 to 34, and to permit hospitals in the remaining 33 voluntary MSAs to choose whether to continue to participate in the model. Additionally, CMS would exempt rural hospitals and low-volume hospitals from mandatory participation.
To allow hospitals eligible for voluntary participation to continue in the model, CMS proposes a one-time voluntary participation election period, beginning January 1, 2018, and ending January 31, 2018. During this time, hospitals which elect to continue in the CJR model can submit a participation election letter to CMS. A hospital’s decision is effective February 1, 2018.
In order to: 1) allow hospitals greater flexibility in alternative payment models, and 2) encourage hospitals to participate in CJR voluntarily, AAMC recommended that CMS:
- Create an additional opt-in period for CJR in January 2019;
- Reduce the regional component of the CJR target price in Performance Years 3-5;
- Reexamine diagnoses and procedures which could qualify for exclusion from CJR; and
- Release programmatic details regarding the next iteration of BPCI by November 1, 2017.
Additionally, AAMC urged CMS to establish more certainty for the provider community regarding the future path to value-based care. AAMC remains committed to supporting the implementation efforts of AMCs that continue to participate in CJR as well as those of providers that pursue other alternative payment models.