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MDMA Submits Comments to CMS on Proposed Changes to Comprehensive Care for Joint Replacement Model

Friday, October 7, 2016  
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MDMA Submits Comments to CMS on Proposed Changes to Comprehensive Care for Joint Replacement Model

MDMA submitted comments today regarding the proposed cardiac rehabilitation incentive payment models and changes to the comprehensive care for joint replacement payment model.

The Centers for Medicare and Medicaid Services (CMS) is proposing a new mandatory cardiac focused episode payment model (EPM) pilot, beginning July 1, 2017, and running five years. Further, CMS is also proposing to extend the Comprehensive Care for Joint Replacement (CCJR) model to include surgical hip/femur fracture treatment (SHFFT).

MDMA recommended that CMS implement the proposed exclusions for new technology add-on payments and pass-through payments. In the past, MDMA has urged CMS to apply similar policies to other bundled payment demonstrations, such as the CCJR and we are pleased that CMS has included them in this proposal. Additionally in the comments letter, MDMA urged CMS not to allow hospitals or accountable care organizations (ACOs) to benefit from gainsharing as cardiac EPM collaborators.

Finally, MDMA urged CMS to extend to a 90-day episode window, noting that in order to ensure that patient care is not compromised over the long term, it is necessary that CMS measure quality over a significantly longer horizon.