The payment reform roller coaster is getting faster and chock-full of surprises! On July 25, 2016 the Department of Health & Human Services (HHS) released a Proposed Rule for:
- Cardiac Care: New Bundle payment models for Cardiac Care.
- Comprehensive Joint Replacement (CJR)-Addendum: An extension of the existing bundle payment model for hip replacements to other hip surgeries.
- Cardiac Rehabilitation: A new model to increase Cardiac Rehabilitation
- Pathway for Physicians: A proposed Pathway for Physicians with significant participation in bundle payment models to qualify for payment incentives under the proposed Quality Payment Program.
Bundled Payment models are conceptually the second most important ingredient to Payment Reform (the first is Value Based Purchasing). These revised and proposed bundle payment models are geared to enhance communication, decrease redundancies, while simultaneously improving the service delivery of and between hospitals, physicians, post- acute care providers, and other clinicians with the ultimate goal of better care at lower cost. At Harmony, we call this “Efficiency” and “Refinement of Resource Allocation.”
Here is an overview of the changes you and your facility should start thinking about for each of the proposed bundled programs:
According to CMS:
“Studies have found completing a rehabilitation program can lower a patient’s risk of heart attack or death. Increasing the use of cardiac rehabilitation services has the potential to improve patient outcomes and help keep patients healthy and out of the hospital. “
This proposed model for Cardiac Care defines the medical as well as the surgical services parameters necessary for an effective bundled payment system
- CMS suggests developing a new Episode Payment Model (EPM) for services surrounding:
- Acute Myocardial Infarction (AMI)
- Coronary Artery Bypass Graft (CABG)
- The EPM will consist of all related care from the time of admission to a participant hospital to 90 day following hospital discharge.
- CMS further defines that the hospital participant with the Cardiac Care model will be in a mandatory 98 randomly selected Metropolitan Statistical Areas (MSAs) the will be chosen by CMS.
- The model is further defined into CMS proposal to test the cardiac model for 5 performance years beginning July 1, 2017 and ending December 31, 2021.
- The hospital participants would be assessed based on quality metrics appropriate to each episode, using both performance and improvement on required measures that are already used in other CMS programs and submission of voluntary data for other quality measure in develop or implementing testing including:
- Heart Attacks
- Bypass Surgery
- Hospital 30-Day, All Cause, Risk– Standardized Mortality Rate following Acute Myocardial Infarction (AMI) Hospitalization and Coronary Artery Bypass Graft (CABG)
- Excess Days in Acute Care after Hospitalization for Acute Myocardial Infraction
- Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) surveys
The above listing is a sample with the voluntary data list for other QM within the Proposed Rule.
Comprehensive Joint Replacement (CJR)- Addendum
CMS also proposed to expand the current Comprehensive Joint Replacement (CJR) payment bundle by adding additional procedures to the mandatory program. The model would also include an episode designed around surgical hip/femur fracture treatment (SHFTT) triggered by discharge data.
Discharge Data would now be collected from Hip and Femur procedures except major joint with complication or co-morbidity (MS- DRG 480) and Hip and Femur procedures except major joint without complications (MS- DRG 481).
CMS final proposed element of the Proposed Rule is the Cardiac Rehabilitation Incentive payment model which would test the impact of providing an incentive payment to hospitals were beneficiaries are hospitalized for heart attack or bypass surgery.
The program will be a two-part incentive payment that will be paid retrospectively based on the total cardiac rehabilitation use of beneficiaries attributable to participant hospitals. The payments were proposed to be available to hospital participants in 45 geographical areas that were not selected for the cardiac care bundle payment models as well as 45 geographical areas that were selected for the bundle models
Pathway for Physicians
The projected regulation also describes new pathways for physicians who partake in bundled payment models (which includes physicians who join forces with hospitals participating in the models) to qualify for financial rewards through the anticipated Quality Payment Program.
These tracks would:
- Require participants to bear risk for monetary losses that meets the proposed nominal risk criteria;
- Use quality measures that meet the proposed measure requirements to base payments; and
- Allow participants to opt into a track that requires use of Certified Electronic Health Record Technology.
Explicitly, the proposed rule would create a track in each model to potentially qualify under the criteria proposed in the Quality Payment Program proposed rule for Advanced Alternative Payment Models (APM’s) beginning in January (CJR) or April (heart attacks and bypass surgery) of 2018 .
When preparing for Bundled Payments it is important for SNF's to understand their Length of Stay (LOS) Data. Harmony Healthcare International (HHI) is here to help. Please contact us by clicking here or calling our office at 1.800.530.4413.
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