This post has been archived and contains information that may be out of date.
CHA has released the attached summary, prepared by Health Policy Alternatives, on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule that would cancel the episode payment models (EPMs) and the cardiac rehabilitation incentive payment model scheduled to begin Jan. 1, 2018.
The rule also proposes to revise aspects of the ongoing Comprehensive Care for Joint Replacement (CJR) model involving mandatory hospital participation, Track 1 clinician eligibility, reconciliation calculation and telehealth service payment.
CMS proposes to reduce the number of mandatory metropolitan statistical areas (MSAs) to include 34 continued mandatory MSAs and 33 voluntary (formerly mandatory) participation MSAs, including two in California: Modesto and San Francisco-Oakland-Hayward. The Los Angeles-Long Beach-Anaheim MSA remains on CMS’ list for mandatory participation.
Additionally, CMS proposes to implement exceptions from mandatory participation for low-volume and rural hospitals in the continued mandatory MSAs. CMS defines low-volume as hospitals with fewer than 20 CJR episodes across the three historical years of data, and lists 28 hospitals in the Los Angeles-Long Beach-Anaheim MSA that meet the criteria.
Low-volume and rural hospitals would automatically be excluded from continued mandatory CJR model participation. Any new hospital with a new CMS certification number existing after the voluntary participation election period would not be required or eligible to join the CJR model.
Three hospital groups would be eligible for CJR model participation on a voluntary basis, beginning in February 2018: hospitals in mandatory MSAs that become voluntary MSAs with CJR model redesign, low-volume hospitals in continued mandatory MSAs and rural hospitals in continued mandatory MSAs.
Hospitals in these groups would have a one-time opportunity to elect to participate voluntarily in the redesigned CJR model for payment years 3, 4 and 5. Each hospital would be required to notify CMS of its election to participate.
A clinician engagement list would be created for participant hospital submission to CMS, expanding the number of clinicians working in CJR Track 1 hospitals that potentially could reach Qualifying Participant status under Medicare’s Quality Payment Program.
CMS recognizes that practice expenses (PEs) ensue during the telehealth visits and proposes to price CJR model postoperative home telehealth visits using facility-level PE values for the corresponding in-person visits. The PE payment would be added to the work and malpractice payments for the corresponding services to set G-code pricing.
CHA invites members to register for a member forum on the proposed rule, scheduled for Oct. 3 from 1-2 p.m. (PT), and seeks member input for its comment letter, which is due Oct. 16. Members should register by noon (PT) on Oct. 2. at www.surveymonkey.com/r/epmcjr.
