CMS Proposes Changes to Bundled Payment Requirements

Last month, the Centers for Medicare and Medicaid Services (CMS) announced a proposed rule which would eliminate the requirement that beginning January 1, 2018, providers would be required to participate in certain mandatory bundled payment programs. The proposed rule seeks to cancel the Episode Payment Models (EPMs) and Cardiac Rehabilitation (CR) incentive payment model, and revise certain aspects of the Comprehensive Care for Joint Replacement (CJR) model. These alternative payment models were created by CMS in 2015 with further bundled payment models created in early 2017. However, CMS had previously delayed their implementation from February 2017 until January 1, 2018.

In the Introduction to the Proposed Rule, CMS states “we believe that canceling the EPMs and CR incentive payment model, as well as altering the scope of the CJR model, offers CMS greater flexibility to design and test other episode-based payment models, while still allowing us to test and evaluate the impact of the ongoing CJR model on enhancing the quality of care while reducing costs.” This change in direction by CMS indicates that it sees the use of bundled payments as a gradual voluntary change, rather than an immediate change as dictated by a specific deadline to use such bundled payments. In addition, CMS states in the Proposed Rule that if the proposal to cancel the EPMs and CR incentive payment model is finalized, “providers interested in participating in bundled payment models may still have an opportunity to do so during calendar year (CY) 2018 via new voluntary bundled payment models.” This statement indicates that while providers will not be required to use bundled payments at this time, they are in no way being eliminated from use.

Many providers believe that bundled payments can lead to better patient care and better quality outcomes. While providers will no longer be required to use these alternative payment models beginning in January 1, 2018, providers should still experiment with voluntary bundled payment models so that they can play a role in evaluating and refining the payment models for future use. Healthcare continues to shift towards value-based care, and those innovative providers who adopt alternative payment models will be able to more easily help shape the future of bundled payments. Contact Frier Levitt today to speak to an attorney.

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