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CHA has submitted the attached comment letter on the Centers for Medicare & Medicaid Services (CMS) Comprehensive Care for Joint Replacement Payment Model proposed rule.
In the letter, CHA urges CMS to consider several important changes to the proposed rule so that hospitals, physicians and post-acute care providers can collectively continue to provide the highest quality care to Medicare beneficiaries while fulfilling the shared goals of the triple aim. Specifically, CHA urges CMS to delay the start date of the program; narrow the 90-day episode definition to only elective joint replacement procedures; further refine the risk adjustment model; and exclude the Hospital Consumer Assessment of Healthcare Providers and Systems survey from the program.
In addition, CHA asks that CMS work with the Health and Human Services Office of Inspector General and other agencies — including the Internal Revenue Service and Federal Trade Commission — to remove all outdated regulatory barriers to clinical integration, noting that these barriers are most substantial in states that ban the corporate practice of medicine, such as California.
CHA’s detailed comments are the result of a robust dialogue with CHA member hospitals. CHA encourages members who have not done so to review the proposed rule summary and listen to the recording of CHA’s member call on the proposal.
