The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule that proposes to cancel the Episode Payment Models (EPMs) and Cardiac Rehabilitation (CR) incentive payment model, as well as rescind the regulations governing these models. Additionally, and of specific significance to occupational therapists, is the proposal to revise certain aspects of the active bundled payment model, Comprehensive Care for Joint Replacement, or CJR. To date, CMS has only released notices of delays relating to these particular bundled payment models and amendments to the existing mandatory model. Now, in addition to the overall cancellation of EPMs, CMS further proposes changes to CJR begin by prospectively making participation voluntary for hospitals in approximately half of the geographic areas selected for participation, reducing the number of mandatory areas from 67 to 34 nationally. CMS is proposing 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 include additional eligible clinicians.
CMS notes that some of its reasoning for these changes is rooted in the belief that requiring hospitals to participate in additional episode payment models at this time is not in the best interest of the agency or the affected providers. CMS expects to continue to offer opportunities for providers who are involved in voluntary initiatives. CMS believes that by reducing the number of providers required to participate in the CJR model, CMS can continue to evaluate the effects of a bundled payment model while limiting the geographic reach.
This proposed rule states that while CMS considered alterations to the design of the EPMs and the CR incentive payment model to allow for voluntary participation, CMS ultimately did not believe providers would be afforded enough time to prepare for such changes, given the planned January 1, 2018, start date. CMS finds these proposed cancellations and changes will afford more flexibility to design and test other episode-based payment models, while still being allowed to test and evaluate the impact of the ongoing CJR model on enhancing the quality of care while reducing costs.
AOTA plans to comment on this proposed rule, due October 16, 2017, and will continue to monitor the outcome of this proposed rule and its potential effects on practitioners who fall under the purview of these and other episodic payment models coming out of CMS. If you are impacted by these changes, AOTA would like to hear from you. Please email us your feedback at email@example.com.
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