The AAMC Sept. 4 submitted comments on the Centers for Medicare and Medicaid Services (CMS) proposed rule on the Comprehensive Care for Joint Replacement Payment (CCJR) Model, which would mandate participation in a lower extremity joint replacement (LEJR) bundled payment program for acute care hospitals in 75 metropolitan statistical areas (MSAs) starting Jan. 1, 2016.
The AAMC supports many of the CCJR proposals, which mirror the design of Model 2 in the voluntary Bundled Payment for Care Improvement (BPCI) initiative. At the same time, the proposed rule raises important questions about the design of a mandatory program for hospitals of many different sizes and types, and at very different points in the “re-design” process. In its comments, the AAMC focuses on the proposed program start date, sharing of claims data, regional pricing concerns, the MSA selection methodology, and the proposed quality metrics.
Regarding the proposed start date, the AAMC urges CMS to push back the program start date to at least Oct. 1, 2016, to allow hospitals adequate time to plan for and implement a risk-based payment model. AAMC notes that hospitals participating in BPCI required at least six to 12 months to prepare for that voluntary program.
The association also raises concerns with CMS’s proposal to only provide beneficiary level claims data to hospitals 60 days after the program start date. The AAMC argues that data must be provided at least six months prior to the program start date to enable hospitals adequate time to identify clinical and financial risks and opportunities.
CMS proposes to calculate hospital target prices through a blend of hospital-specific and regional data for performance years one through three, and shift to 100 percent regional-based pricing in years four and five. The AAMC opposes this proposed timeline and notes that regional pricing is not tenable for many hospitals, nor an appropriate pricing model for other clinical conditions.
However, the association acknowledges that highly efficient providers may thrive under regional pricing. The AAMC recommends that CMS adopt a target price methodology that assigns a hospital a target price that is the higher of the hospital-specific methodology or the proposed blended hospital-specific/regional methodology.
Regarding the quality measures in the program, CMS proposes that to qualify for savings, hospitals must meet or exceed a performance threshold on a total hip arthroplasty/total knee arthroplasty (THA/TKA) readmissions measure, THA/TKA complications measure, and the Hospital Consumer Assessment of Healthcare Provider Systems (HCAHPS) survey. The AAMC urges CMS to remove the HCAHPS survey from program, since it is much broader than THA/TKA episodes of care. The AAMC also recommends that the measure be assessed with confidence intervals and that improvement be incorporated into the CCJR program.
The final rule is expected to be released in late Fall 2015.