HFMA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the Advancing Care Coordination Through Episode Payment Models (EPMs) proposed rule, published in the August 2, 2016, Federal Register.
HFMA fully supports CMS’s goal of transitioning 50 percent of Medicare fee-for-service (FFS) payments to value-based arrangements (such as the payment models proposed in the EPM rule). And while the proposed EPM rule incorporates several significant improvements to CMMI’s episodic payment models, facets of the proposed EPM rule concern HFMA’s members. Specifically, our members are concerned about the lack of sufficient risk adjustment to all of the proposed episodes, the lack of relevant quality measures for the SHFFT episode, and the additional, unnecessary administrative burden that, as proposed, these episodes would place on hospitals. As such, HFMA recommends that CMS delay implementation of the EPM rule 24 to 36 months to give CMS time to address these issues.