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Association Responds to Final Rule Delaying Cardiac, Joint Models

In an April 19 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals expressed support of the delay of episode payment models (EPMs) to allow selected hospitals more time to prepare for participation.

In its final rule with comment period, CMS delayed until Oct. 1 the implementationof new EPMs for cardiac care and extension of the joint model, as well as amendatory provisions to the existing joint model, and sought comment about further delay until Jan. 1, 2018.

In its letter, America’s Essential Hospitals recommended that CMS:

  • limit the size and scope of demonstrations and develop voluntary models to reduce burden on providers and ensure patient safety;
  • consider the readiness of providers and resources required to achieve care coordination among patients with social risk factors;
  • further delay until Jan. 1, 2018, the final rule on EPMs, including expansion of the Comprehensive Care for Joint Replacement (CJR) model;
  • not delay beyond Oct. 1 the implementation of amendatory provisions affecting active demonstrations — i.e., the CJR model; and
  • appropriately adjust the quality measures in these models to account for social risk factors and monitor for any unintended consequences of participation by essential hospitals.

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


About the Author

Maryellen Guinan is a principal policy analyst at America's Essential Hospitals.

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