The AAMC October 3 submitted a comment letter in response to the Centers for Medicare and Medicaid Services (CMS) on the Advancing Care Coordination Through Episode Payment Models (EPMs) proposed rule. This proposal, if finalized, would establish a new mandatory bundled payment program starting July 2, 2017.
Under the EPMs proposed rule, the hospital in which a patient is admitted for care for an acute myocardial infarction (AMI), coronary artery bypass graft (CABG) surgery, or surgical hip/femur fracture treatment (SHFFT) would be accountable for the cost and quality of care provided to Medicare fee-for-service beneficiaries during the inpatient stay and for 90 days post-discharge. Hospitals located in the 67 metropolitan statistical areas (MSAs) required to participate in the Comprehensive Care for Joint Replacement Model (CJR) will be required to participate in SHFFT. Meanwhile, hospitals located in 98 yet-to-be selected MSAs will be required to participate in the CAGB and AMI episodes.
As outlined by CMS, hospital financial performance will be retrospectively compared to target prices, which will be a blend of hospital-specific and regional data, moving to 100 percent regional pricing in years four and five of the program. In order to receive savings, participants must achieve a certain quality composite score that will be based on performance, improvement, and voluntary reported patient outcome measures.
In its comment letter, the AAMC notes its support for voluntary bundled payment programs over those that require mandatory participation. The Association comments in favor of many aspects of the proposed program design, including the definition of the AMI episode, which was broadened from previous bundled payment programs to incorporate patients with a percutaneous coronary intervention (PCI). In addition, AAMC applauds CMS’s proposal to make EPMs eligible to qualify as an Advanced Alternative Payment Model (APM) under the Quality Payment Program (QPP).
The AAMC recommends numerous changes that would better enable hospitals to realize success under EPMs. Namely, the Association recommends that CMS extend the “no downside” risk period of the program from 6 months to 12 months. The Association also expresses concern regarding the rapid shift to 100 percent regional pricing. Finally, the AAMC presents a series of proposed alterations to the quality measures and scoring methodology, arguing that quality metrics that do not directly relate to the care provided or are not NQF-endorsed or publicly reported should not be included in this program.