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CHA has submitted the attached comment letter on the Centers for Medicare & Medicaid Services’ (CMS) interim final rule delaying implementation of certain episode payment models (EPMs) from July 1 to Oct. 1. The EPMs delayed by the interim final rule include those focused on episodes of care for acute myocardial infarction, coronary artery bypass graft and surgical hip/femur fracture treatment (SHFFT) excluding lower extremity joint replacement, as well as the Cardiac Rehabilitation Incentive Payment Model. CHA supports the delay and offers CMS a number of other policy issues to consider as the agency proceeds in testing EPMs.
In its letter, CHA urged CMS:
- Not to proceed in expanding SHFFT episodes in the Comprehensive Care for Joint Replacement (CJR) model as a mandatory requirement and to make the inclusion of SHFFT episodes voluntary for CJR participants
- To reconsider its mandatory implementation of the cardiac EPM and proceed instead with a voluntary model. However, if CMS keeps the program as mandatory, CHA urged CMS to further delay the start of the model to Jan. 1, 2018.
- To improve quality measures selected for all EPM models and implementation of smaller discount factors in the cardiac model than currently proposed
