CHA Association Supporter

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.

The Centers for Medicare & Medicaid Services (CMS) has issued the attached interim final rule with comment period delaying, by three months, implementation of its new mandatory episode-based payment model (EPM) for cardiac care and expansion of the current Comprehensive Care for Joint Replacement (CJR) model to include surgical treatments for hip and femur fractures beyond hip replacement. The interim final rule, which was issued to give the Trump Administration additional time to review the original final rule consistent with the administration’s regulatory freeze, delays the implementation date of these models from July 1 to Oct. 1. It also further delays certain provisions for a second time, from March 21 to May 20. In addition, CMS seeks comments on the appropriateness of the delay, and whether implementation of the new models should be delayed further until Jan. 1, 2018. CHA anticipates that CMS will make fairly significant modifications to these programs through separate rulemaking in the very near future, and will respond during this 30-day comment period. As providers await more details from CMS, CHA is interested in learning from members about the programs’ opportunities and challenges and changes that are needed. Contact Alyssa Keefe, CHA vice president, federal regulatory affairs, at akeefe@calhospital.org or (202) 488-4688 with feedback.    

CHA reminds hospitals participating in the Comprehensive Care for Joint Replacement (CJR) Model to provide the Centers for Medicare & Medicaid Services (CMS) with a list of previous and current CJR collaborators as of Feb. 28. Participating hospitals are required to provide CMS with “evidence sufficient to enable the audit, evaluation, inspection, or investigation of the individual’s or entity’s compliance with CJR requirements, the quality of services furnished, the obligation to repay any reconciliation payments owed to CMS, or the calculation, distribution, receipt, or recoupment of gainsharing payments, alignment payments, or distribution payments.” CJR participant hospitals should complete the attached Excel form and submit to CJRsupport@cms.hhs.gov by 5 p.m. (PT) on March 21.

CHA has submitted the attached comment letter on the Centers for Medicare & Medicaid Services (CMS) proposed rule specifying necessary qualifications practitioners must meet to furnish and fabricate prosthetics and custom-fabricated orthotics. Noting that the proposed rule would impose additional burden on hospitals, and is inconsistent with the Trump Administration’s commitment to reducing regulatory burden, CHA urges CMS to withdraw rather than finalize the proposed rule. If CMS moves forward in finalizing the rule, CHA urges CMS to make changes to its proposed policies. Specifically, CHA urges CMS to exempt occupational and physical therapists from certain certification requirements and to make changes to its fabrication facility requirements. Comments on the proposed rule are due March 13 by 5 p.m. (PT).

CHA seeks member input on a Centers for Medicare & Medicaid Services (CMS) proposed rule specifying necessary qualifications practitioners must meet to furnish and fabricate prosthetics and custom-fabricated orthotics. The rule would also address the qualifications and accreditation requirements suppliers must meet in order to fabricate and bill for the same devices. In addition, the rule sets forth a time frame by which qualified practitioners and suppliers must meet the rule’s requirements. CHA is developing its comment letter and seeks input from members on how the provisions in this proposed rule would impact their operations. Comments and questions should be directed to Megan Howard, CHA senior policy analyst, at mhoward@calhospital.org.

On Jan. 20, the Trump Administration issued a memo to the heads of all executive departments and agencies freezing new and pending federal regulatory activity until the President's appointees or designees have had the opportunity to review any new, recently finalized or pending regulations. The memo, which is common for an incoming administration, addresses regulations that have been sent to the Office of the Federal Register but not yet published, as well as regulations that have been published in the Federal Register but were not yet effective on Jan. 20. The memo instructs federal agencies to withdraw any regulation not yet published for review and approval by the Trump Administration. In addition, it temporarily postpones the effective date of any regulations that were not yet in effect by Jan. 20 for at least 60 days following the issuance of the memo, subject to review and approval by Trump appointees.

The Centers for Medicare & Medicaid Services has published the attached Medicare Learning Network Matters article about the waiver of the three-day qualifying stay for post-hospital care provided in a skilled-nursing facility (SNF) under the Comprehensive Care for Joint Replacement model. The article addresses policies related to the waiver and how services should be billed, and describes conditions that must be met for coverage of the SNF stay.