Word spread quickly Monday (December 20, 2016) about CMS’ issuance of final regulations (to be published in the Federal Register on January 3, 2017) rolling out new mandatory bundled payments models for Acute Miocardial Infarction (AMI), Coronary Artery Bypass Graft (CABG), Surgical Hip and Fracture Treatment (SHFFT), a Cardiac Rehabilitation (CR) incentive model and Track 1+ Accountable Care Organizations. Speculation that President-elect Donald Trump’s nominee for HHS secretary, Rep. Tom Price, would move to roll the regulations back spread just as quickly.
The new regulations mandate bundled payment models (covering the period from admission to ninety days post-discharge) for AMI and CABG in 98 geographies covering 1,120 hospitals; for SHFFT in the 67 geographies where the Comprehensive Joint Replacement (CJR) has already been mandated covering 850 hospitals and for CR in 90 geographies covering 1,320 hospitals. CMS’ chart of geographies covered by each program is set forth here. The AMI, CABG and SHFFT programs give participant clinicians the opportunity to be excluded from Medicare and CHIP Reauthorization Act of 2015’s (MACRA) Medicare Incentive Payment System (MIPS) and to qualify under MACRA’s Advanced Alternative Payment Model (AAPM).
CMS also provided some detail (with the promise of more critical detail to come) about the new Track 1 + Medicare Shared Savings Program (MSSP) track it had announced several months ago with the final regulations under MACRA. The new track, which will begin in 2018, has more limited downside risk than the existing dual sided risk tracks in the MSSP while still giving the participant clinicians in the track the opportunity to be excluded from MIPS and to qualify under AAPM. CMS made some changes to the CJR bundled payment model to allow participants in that model to qualify as early as 2018 under MACRA’s AAPM as well.
While the outgoing administration continues to push its bold pay-for-value agenda with the newly finalized programs, major industry stakeholders like the American Hospital Association have issued statements indicating that these changes may be too much too soon. Perhaps more importantly, Rep. Tom Price, Donald Trump’s nominee for HHS Secretary has publicly raised concerns about CMS’ bundled payment programs and the final MACRA regulations published by CMS earlier this year. In January, the provider industry will be watching and waiting to see whether the news programs, and perhaps the MACRA regulations themselves, are ever implemented.