In the letter, HFMA states that our members strongly support delaying the start of the cardiac and hip fracture episodes described in the EPM interim final rule (IFR). At this time, the bundles included in the EPM IFR do not reflect the principles HFMA has articulated for “fair and rational” payment models. In our comment letter related to the proposed rule, HFMA’s members identify specific technical design flaws with those bundles. The most significant issues identified are:
- Lack of risk adjustment
- Insufficient episode exclusions
- Insufficient access to Medicare claims data in a timely fashion
- Insufficient (or inapplicable) quality measures
- Inadequate waivers from antiquated fraud-and-abuse regulations that were designed to address the volume incentives inherent in fee-for-service-payments
As for CJR, CMS delays the effective date of finalized changes to the model to October 1, 2017. HFMA encourages CMS not to delay these changes further. These adjustments create a pathway for the CJR program to be considered an Advanced Alternative Payment Model (AAPM) under the Medicare Access and CHIP Reauthorization Act (MACRA).