October 01, 2017

CMS Applies the Brakes to Mandatory Bundled Payment Models: Proposed Rule to Revise the Comprehensive Care for Joint Replacement Model and Cancel the Episode Payment Models and Cardiac Rehabilitation Payment Model

Briar Siljander and Jennifer Gross, Cooper & Riesterer, PLC, Brighton, MI

The Centers for Medicare & Medicaid Services (CMS) published a proposed rule on Thursday, August 17, 2017 (Proposed Rule)1 that, if adopted without significant change, will cancel three bundled payment models and a post-cardiac episode incentive model before their launch, and shrink the scope of another bundled payment model as it approaches its third year in effect. The Proposed Rule rescinds the Episode Payment (EP) models and Cardiac Rehabilitation (CR) Payment model, which were set to take effect January 1, 2018, and will alter the Comprehensive Care for Joint Replacement (CJR) model, most notably by cutting in half the number of mandatory participating regions. Heeding the call of stakeholders, the Proposed Rule signifies a shift from a mandatory, regulatory rule-making approach to healthcare delivery and payment to one emphasizing voluntary participation and partnership.

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