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Association Objects to Required Participation in Bundled Payment Model

America’s Essential Hospitals called on the Centers for Medicare & Medicaid Services (CMS) to consider the readiness of essential hospitals and the unique challenges inherent in caring for the nation’s most vulnerable patient populations in finalizing its proposed rule requiring selected hospitals to participate in the Comprehensive Care for Joint Replacement (CCJR) Model- a bundled payment model for hip and knee replacement.

In our comments to CMS, the association objected to the requirement that hospitals participate in a payment model test. We urged CMS to consider factors related to a hospital’s capability and readiness to implement care redesign activities when selecting participants for the CCJR Model.

Under the proposed rule, hospitals would be required to meet or exceed quality performance thresholds on three measures before they are eligible to receive reconciliation payments. The association urged CMS to risk-adjust for sociodemographic factors in these measures to provide an accurate representation of hospital quality of care without unduly penalizing essential hospitals. Additionally, we urged CMS to adopt an alternative to the proposed quality thresholds, one that aligns with current quality reporting and provides hospitals that don’t meet the thresholds the opportunity to receive reconciliation payments while continuing their quality improvement efforts through an improvement plan.

While the association supports care coordination to improve outcomes, we made specific note of the financial commitment hospitals would have to make to participate and the need for CMS to provide reconciliation payments, without excessive barriers, to allow hospitals to redirect savings back into care redesign and coordinated care processes.

Contact Erin O’Malley, director of policy, at eomalley@essentialhospitals.org or 202.585.0127 with any questions.

 

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About the Author

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

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