CMS proposes cancelling, scaling back mandatory bundled payment programs

Two bundled payment programs could be canceled before they begin, and the scope of a third will be significantly limited if a proposed rule released by CMS August 17 is finalized.

The agency proposes cancellation of Episode Payment Models (EPM) and the Cardiac Rehabilitation (CR) incentive payment model in the rule. In addition, CMS proposes to make participation in the Comprehensive Care for Joint Replacement model (CJR) voluntary in 33 of the 67 geographic areas where participation is currently mandatory. The agency also suggests making participation in the CJR voluntary for low-volume and rural hospitals in all areas.

The EPM and CR models were mandatory programs for certain providers that were originally scheduled to begin months ago, but multiple delays pushed that start date back to January 1, 2018. The models were created to institute bundled payments for episodes of care for treatment of acute myocardial infarctions, coronary artery bypass grafts, surgical hip and femur fractures, and cardiac rehabilitation by linking payment to quality outcomes.

Participation in the CJR model began in April 2016, and therefore CMS will not cancel that program but proposes to substantially reduce the number of providers who must participate.

While cutting these programs may seem like a shift away from value-based care, CMS said in a press release that it hopes canceling these programs would allow stakeholders to devote time and resources toward creating other episode-based models.

The press release also emphasizes introducing more voluntary initiatives, a move which would address provider comments in response to the mandatory nature of the EPM, CR, and CJR programs in certain regions.

The proposed rule does raise questions for providers as to how they will choose to participate in the Quality Payment Program under the Medicare Access and CHIP Reauthorization Act (MACRA). All three programs would have eventually provided a participation option under the QPP as an Advanced Alternative Payment Models (APM). CJR already qualifies as an APM, and should this rule become finalized, providers located in the 33 geographic areas where participation in CJR would become voluntary will need to decide whether they wish to continue participating in CJR in order to continue to receive the positive payment adjustments available under the QPP through the APM track.

Any provider planning to participate in the QPP through the APM payment pathway under the EPM or CR model would likely need to find an alternative way of participating should the rule become finalized.  

Comments on the proposed rule are due by October 16.