Updates
March 2017
Medicare Mandatory Bundled Payments Rule: Minor Aspects Delayed, Others On-Schedule for July Implementation

In a move the Centers for Medicare & Medicaid Services cites as a reaction to President Donald Trump’s regulatory freeze, CMS announced that implementation of certain minor aspects of the final rule expanding Medicare mandatory bundled payment models will be delayed by approximately one month.
  
The final rule is titled “Advancing Care Coordination Through Episode Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and Changes to the Comprehensive Care for Joint Replacement Model (CJR)” – and this announcement now delays implementation of certain minor parts from February 18, 2017 until March 21, 2017. Those parts include: 
  • Clarification of overlap between mandatory bundled payment programs and existing accountable care organization based models
  • Adjustments to quality score methodology in the ongoing CJR program
  • Establishment of tracks in the CJR program which will be deemed to meet criteria for advanced alternative payment models under MACRA
While not immediately apparent in the announced rule, published February 17, 2017, the launch date for other significant parts of the final rule, including the new EPMs, the new incentive payment model associated with cardiac rehabilitation, and the expansion of the CJR program to hip and femur fractures will not be changed, and is set for July 1, 2017 – a fact later confirmed by an HHS spokesman.  As such, while the uncertainty continues, hospitals in designated MSAs should continue preparations for participation in the EPMs and the expanded version of CJR.

To view the full alert, click here.

To learn more about our Health Care Services practice, click here.