This post has been archived and contains information that may be out of date.
CHA has prepared the attached first-glance summary of the Centers for Medicare & Medicaid Services (CMS) final rule implementing the Comprehensive Care for Joint Replacement (CJR) payment model. As noted when the rule was issued, CMS has finalized the start date for this program to April 1, 2016, a slight delay from the proposed start date of Jan. 1, 2016. The model will require participation from inpatient prospective payment system hospitals in three California metropolitan statistical areas, as proposed.
In response to comments submitted by CHA and others, CMS finalized its episode definition with slight modification. CMS has responded to concerns regarding the inclusion of emergent hip fractures by finalizing a policy to risk stratify the target price. CMS will use a retrospective payment methodology with no risk to the hospitals in year one; however, there will be financial risk to the hospital in years two through five. CMS also reduced the limits it sets on hospitals’ repayment responsibility to Medicare and modified its proposed stop-gain policy that limits hospitals’ reconciliation payments.
CMS also finalized a number of waivers in connection with the CJR model, including the “incident to” rule, some geographic site requirements for telehealth payment, and the skilled-nursing facility three-day rule with certain requirements. CMS did not waive the home health home bound requirement, the inpatient rehabilitation facility 60 percent rule or discharge planning requirements. In addition, CMS and the Department of Health and Human Services Office of Inspector General issued a joint statement that waives the federal anti-kickback statute and the physician self-referral law with respect to certain financial arrangements.
CHA continues to analyze the final rule and will provide members a more detailed summary in the coming weeks. CHA will also schedule a member call to review the provisions of the final rule and will issue DataSuite analyses on the rule’s impact. Additional information will be shared in CHA News.
