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Association Comments on Proposal to Cancel Episode Payment Models

In an Oct. 16 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals commented on a proposed rule that, if finalized, will cancel mandatory episode payment models (EPMs) for cardiac care and surgical hip/femur fracture, as well as the cardiac rehabilitation (CR) incentive payment model.

The proposal also would reduce the overall number of participants in the Comprehensive Care for Joint Replacement (CJR) model. Specifically, CMS proposes reducing the number of mandatory geographic areas participating in the CJR model from 67 to 34 and allowing participants in the remaining 33 areas to participate on a voluntary basis.

In its comments to CMS, America’s Essential Hospitals recommended that the agency:

  • finalize the cancellation of the EPMs, including the expanded CJR model and the CR incentive payment model;
  • limit the size and scope of the CJR model and consider the resources necessary for providers still required to participate;
  • work with stakeholders to develop voluntary models that encourage participation by essential hospitals and recognize the resources required for improved care coordination and cost savings; and
  • mitigate concerns about the effect of proposed removal of total knee arthroplasty procedures from the inpatient only list on the CJR model.

Contact Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Rachel Schwartz is a former policy associate at America's Essential Hospitals.

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