With the effective date for the Comprehensive Care for Joint Replacement (“CJR”) program now upon us, we wanted to take a moment to highlight key steps that affected hospitals should be pursuing if they wish to realize the benefits of – or at a minimum, avoid potential adverse consequences of – this new payment model.
Beginning April 1, 2016, hospitals in 67 metropolitan statistical areas (“affected hospitals”) will be subject to the CJR Payment Model for Lower Extremity Joint Replacement Services (LEJR). Although April 1 marks the start date for the CJR program, hospitals will not be subject to the program’s down-side risk until the 2017 performance year. Nevertheless, there are steps that affected hospitals must or should be taking immediately.
- Beginning April 1, provide written notice, upon admission to the hospital or immediately following the decision to schedule LEJR, to any Medicare beneficiary who meets the criteria for CJR. (A Beneficiary Notification form is available on the CMS website.)
- Maintain a list of all beneficiaries that receive a Beneficiary Notification.
- Provide CMS with the hospital’s “designated points of contact” (to get access to information and materials such as the Beneficiary Notification Form and Data Request and Attestation Forms).
- Request, review, and analyze claims and quality data from CMS.
- Identify opportunities and strategies to reduce overall costs, improve quality, and generate Internal Cost Savings.
- Develop a plan for Care Redesign.
- Identify in-kind patient engagement incentives (if any) to advance one or more of the goals of the CJR program.
- Identify potential CJR Collaborators – i.e., post-acute care providers (SNFs, HHAs, LTCHs, and IRFs), physicians, non-physician practitioners, and outpatient therapy services providers and suppliers who will participate in Care Redesign.
- Prepare written policies and procedures for CJR Collaborator selection, including quality criteria.
- Develop CJR Collaborator agreements, including a Sharing Arrangement for payment of Gainsharing Payments to, and receipt of Alignment Payments from, CJR Collaborators.
- Post a list of CJR Collaborators on the hospital’s website and include this list in the Beneficiary Notification.
- Implement a compliance program (or amend the hospital’s Corporate Compliance Plan) to address CJR and Sharing Arrangements.
These are no small tasks. Each requires careful adherence to the often complex requirements of the Final Rule. Perhaps more importantly, these steps require coordination and close cooperation both among and within the hospital and its CJR Collaborators. All participants in this program must learn how to meld data analysis, clinical processes, and compliant financial arrangements in a way that results in better, more cost-effective care.
Although start-up and implementation of the CJR Program may prove painful for hospitals, it can also be viewed as an opportunity. The types of care transformation and provider relationships required by CJR are a harbinger of things to come for health care delivery in general. The CJR program offers a microcosm of care in which providers can learn how to do these difficult tasks on a small scale, before similar bundled payment models are applied to other episodes of care.