WHA Comments on CMS’ Proposed Changes to Bundled Payments

October 20, 2017

On October 16, WHA submitted comments to the federal Center for Medicare and Medicaid Services (CMS) on a proposed rule issued by CMS in August, in which CMS signaled its intent to implement flexibilities within value-based payment programs. WHA expressed support for the partial conversion of mandatory bundled payment models into voluntary programs, as voluntary participation in program innovation is always preferable to a mandate. However, WHA also noted how value-based payment programs have spurred innovation in our state

In late 2015, hospitals in both the Madison and Milwaukee Metropolitan Statistical Areas (MSAs) were selected to be mandatory participants in CMS’s Comprehensive Care for Joint Replacements (CJR) bundled payment program. Wisconsin’s high-performing health systems have generally embraced the challenges presented by the mandatory CJR bundle, and many are experiencing positive results from years 1 and 2 of the CJR.

In the proposed rule, CMS announced plans to prospectively make participation voluntary for all hospitals in approximately half of the geographic areas in the CJR model, including hospitals in Wisconsin. The rule also proposes several technical refinements and clarifications for certain CJR model payment, reconciliation, and quality provisions, and a change to the criteria for the Affiliated Practitioner List to broaden the CJR Advanced Alternative Payment Model (APM) track to additional eligible clinicians. Additionally, the rule proposes to cancel the Episode Payment Models (EPMs) and the Cardiac Rehabilitation (CR) incentive payment model, established by the Center for Medicare and Medicaid Innovation (Innovation Center). These were scheduled for implementation in 2018.

If the changes in the proposed rule are finalized, hospitals in Wisconsin that are currently participating in CJR will be able to make a choice about continuing to participate. Many of these hospitals will continue to do so because they have already made invested time, infrastructure and resources with very positive results for improved care coordination and overall quality. This includes markedly improved coordination of care both within the organizations and with outside entities such as post-acute care providers.

With a new direction evident at CMS, what’s next for bundled payments?  Bundled Payments for Care Improvement (BPCI), another CMS program which will expire in 2018, has been successful and will likely be followed soon by a new, voluntary bundled payment program, BPCI-Advanced. CMS expects a high amount of interest in BPCI-Advanced because it will qualify as an APM, which exempts participating physicians from potential payment reductions they could face under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

CMS has also issued a Request for Information (RFI) for feedback on a new CMS direction to promote patient-centered care and to test market-driven reforms that “empower beneficiaries as consumers, provide price transparency, increase choices and competition to drive quality, reduce costs, and improve outcomes.”

WHA will submit feedback to this RFI by November 20. For further information, contact Laura Rose, WHA vice president, policy development, at lrose@wha.org.

This story originally appeared in the October 20, 2017 edition of WHA Newsletter