On January 9, 2018, the Centers for Medicare & Medicaid (CMS) Center for Medicare and Medicaid Innovation announced a new voluntary bundled payment model called Bundled Payments for Care Improvement Advanced (BPCI Advanced).  BPCI Advanced is the first Advanced Alternative Payment Model (Advanced APM) launched under the Quality Payment Program that was implemented as part of the Medicare Access and Chip Reauthorization Act (MACRA). 
Continue Reading CMS Announces First Advanced Alternative Payment Model Under MACRA: Bundled Payments for Care Improvement Advanced

The Centers for Medicare and Medicaid Services (CMS) recently published a proposed rule (Proposed Rule) to scale back its mandatory bundled payment programs. Under the Proposed Rule, CMS would cancel the episode payment models (EPMs) and cardiac rehabilitation incentive payment model (CR), and it would also reduce the mandatory participation in the comprehensive care for joint replacement model (CJR). CMS stated that it believed the proposed changes are necessary because the continued mandatory participation in bundled payment models may impede CMS’s ability to engage providers in future, voluntary initiatives. CMS also stated that it anticipates testing future initiatives through applications and agreements with providers as opposed to additional rulemaking efforts.
Continue Reading CMS Proposes to Cancel EPM and CR Bundled Payment Programs and to Reduce Mandatory Participation in CJR Model

On February 17, 2017, the U.S. Department of Health & Human Services (HHS) announced that it had delayed the effective date of provisions of a Centers for Medicare & Medicaid Services (CMS) Final Rule that were scheduled to take effect February 18, 2017.  The Final Rule – titled “Advancing Care Coordination through Episode Payment Models” – was issued January 3, 2017 (see our previous analysis here) and in pertinent part implements:

  • Three new Medicare episode payment models (EPMs) surrounding 90-day episodes of care arising from (a) an acute myocardial infarction (AMI), (b) a coronary artery bypass graft (CABG), or (c) a surgical hip/femur fracture treatment (SHFFT);
  • An incentive payment model to spur increased utilization of cardiac rehabilitation and intensive cardiac rehabilitation for Medicare beneficiaries; and
  • Modifications to the Comprehensive Care for Joint Replacement model (CJR Model), an ongoing CMS payment model involving hip and knee replacements that started on April 1, 2016.


Continue Reading HHS Delays Effective Date of Key Provisions in CMS Final Rule “Advancing Care Coordination through Episode Payment Models”

In December, the Centers for Medicare & Medicaid Services (CMS) issued a final rule (Final Rule) implementing new and revised episode payment models (EPMs) developed by the CMS Innovation Center.  The Final Rule continues CMS’ transition of Medicare payment methodologies away from fee-for-service and towards value-based payments, including by incentivizing care coordination efforts and tying payments to quality improvement.

New EPMs:  The Final Rule implements three new EPMs for episodes of care surrounding (i) acute myocardial infarction (AMI); (ii) coronary artery bypass graft (CABG); and (iii) surgical hip/femur fracture treatment excluding lower extremity joint replacement (SHFFT). Each episode of care encompasses a beneficiary’s inpatient stay as well as all related care within 90 days after discharge covered under Medicare Parts A and B. The initial performance year for the EPMs will start July 1 and expire December 31, 2017, and be followed by four successive performance years (2018-2021). Participation in the AMI and CABG EPMs will mandatory for acute care hospitals located in 98 randomly-selected metropolitan statistical areas (MSAs), and participation in the SHFFT EPM will be mandatory for hospitals in the 67 MSAs that currently participate in CMS’s comprehensive care for joint replacement model (CJR Model). The EPMs are designed to incorporate downside risk starting in 2019, but allow participants to assume downside risk in 2018 in order to qualify for potential incentive payments under the Medicare Access and CHIP Reauthorization Act (MACRA), by participating in an Advanced Alternative Payment Model.
Continue Reading CMS Final Rule on Episode Payment Models and Revisions to CJR Model

On November 4, 2016, the Centers for Medicare & Medicaid Services (CMS) published a final rule with comment period (Final Rule) implementing the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The Final Rule overhauls the methodology by which most physicians and certain other clinicians participating in Medicare will be reimbursed and marks a significant shift away from fee-for-service payments and toward value-based reimbursement. Under the Final Rule, CMS created the Quality Payment Program (QPP), which incorporates components of the Physician Quality Reporting System (PQRS), the Medicare Electronic Health Record Incentive Program for Eligible Professionals (commonly known as Meaningful Use), and the Physician Value-Based Payment Modifier (VM).
Continue Reading CMS’ Final MACRA Rule Continues Transition Toward Value-Based Payments