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CHA has submitted the attached comment letter on the Centers for Medicare & Medicaid Services (CMS) proposed rule implementing episode payment models (EPMs) for cardiac care and expanding the current comprehensive care for joint replacement (CJR) model to include surgical treatments for hip and femur fractures (SHFFT) beyond hip replacement. While CHA shares the administration’s ambitious goals of moving the health care system from fee-for-service to a value-based system, CHA raises serious concerns over the pace of unprecedented change threatening hospitals’ progress to date.
In light of the operational realities of implementing the proposed model in the context of the other regulatory changes required of hospitals, CHA urges CMS to delay implementation of the cardiac EPM model until it completes its final round of voluntary reporting by Bundled Payments for Care Improvement participants. In addition, CHA does not support the proposed expansion of the CJR program to SHFFT episodes beginning July 1, 2017. CHA also urges CMS to exclude CJR hospitals from inclusion in any future implementation of the cardiac EPM model. Finally, CHA urges CMS to consider how a future EPM model could be simplified and streamlined to limit the implementation complexities, bringing a more common sense approach to operationalization of these programs.
