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In 2016, the Centers for Medicare and Medicaid Services (CMS) put forth a proposed rule for bundled payment models for Medicare fee-for-service beneficiaries receiving services during acute myocardial infarction and coronary artery bypass graft, two very common cardiac procedures. In addition, the Proposed Rule modifies the Comprehensive Care for Joint Replacement (CJR) bundled payment program by including surgical hip/femur fracture treatment episodes, and is based on the CJR model.   

Comments from professional societies, patient organizations and health care coalitions focused on the cardiac rehabilitation incentive payments, the definition of “episode of care” under the rule, the qualifications of the bundle holder, financial relationships between the acute care hospitals and post-acute care providers, quality measures, and scope of implementation. They also urge CMS to slow the process so they can thoroughly assess the multiple bundled payment models it is currently implementing, before implementing additional bundling programs, in order to assess the impact on beneficiary access to quality healthcare, including rehabilitative services and devices. These groups also believe CMS is expanding the bundling program(s) without looking at any data from the initial roll out. In simple terms, they are doing too much too soon. 

Summary of CMS Comments

“After careful consideration of the public comments received, we are finalizing a further delay of the start date of the EPMs and CR incentive payment model until January 1, 2018, such that these models’ performance year 1 would start on January 1, 2018 and end on December 31, 2018. Additionally, we are finalizing a further delay of the effective date of the CJR regulation amendments that were to take effect October 1, 2017. These CJR regulation amendments will now be effective as of January 1, 2018, to maintain our policy of aligning these changes with the EPMs."

"We also note that we disagree with commenters who suggested that CMS withdraw these models altogether and/or delay them indefinitely. As we stated in the January 3, 2017 EPM final rule, we believe these models will further our goals of improving the efficiency and quality of care for Medicare beneficiaries receiving care for these common clinical conditions and procedures."