The American Hospital Association supports the Comprehensive Care for Joint Replacement payment model that CMS proposed in July. However, the AHA recommended several ways CMS could improve the model in comments submitted to CMS on Sept. 8.
Through the proposed five-year Comprehensive Care for Joint Replacement payment model, hospitals would continue to be paid under existing Medicare payment systems. However, the hospital where the hip or knee replacement takes place would be held accountable for the quality and cost of care from the time of surgery through 90 after discharge.
Under the payment model, hospitals would be eligible to receive an additional payment or be required to repay Medicare for a portion of the episode costs depending on the quality of care the hospital provides and its cost performance.
The AHA said the payment model could help further hospital efforts to improve care coordination and cost accountability, but it believes there needs to be some protections put in place for provider organizations, including a Stark Law and Anti-Kickback Statute waiver.
"As proposed, any financial arrangement or agreement under the CCJR model that implicates fraud and abuse laws would not be protected unless it falls under an existing exception or safe harbor," noted AHA Executive Vice President Tom Nickels in the comments submitted to CMS. "That is unacceptable risk for hospitals, whose participation in this program would be mandatory."
The AHA also urged CMS to delay the program's start date to give hospitals more time to put the processes and procedures in place "to achieve success in the program." The proposed start date for the program is Jan. 1, 2016, and the AHA recommended a July 1, 2016 start date.
In addition, the AHA recommended CMS restrict the program to elective hip and knee replacement episodes and incorporate a risk-adjustment methodology.
The AHA's comments to CMS regarding the payment model can be found here.
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