/ en Wed, 30 Apr 2025 17:04:38 -0500 Mon, 10 Jun 24 15:33:24 -0500 /news/headline/2024-06-10-aha-urges-cms-make-transforming-episode-accountability-model-voluntary <p>The AHA expressed <a href="/lettercomment/2024-06-10-aha-comments-cms-proposed-transforming-episode-accountability-model-team">concerns</a> June 10 to the Centers for Medicare & Medicaid Services about its proposed Transforming Episode Accountability Model (TEAM), saying it "is proposing to mandate a model that has significant design flaws, and as proposed, places too much risk on providers with too little opportunity for reward in the form of shared savings, especially considering the significant upfront investments required." The proposed mandatory payment model would bundle payment to acute care hospitals for five types of surgical episodes, which comprise over 11% of inpatient prospective payment system payments (not including outpatient payments that would also be at risk in the model). The association urged CMS to make model participation voluntary, reduce the discount factor from 3% to no more than 1%, and make several significant changes to design elements, otherwise CMS should not implement the model. 鈥淚f CMS cannot make extensive changes to the model, it should not implement it at this time,鈥� AHA wrote. 鈥淭o do so would make TEAM no more than a thinly disguised payment cut, as it fails to provide hospitals a fair opportunity to achieve enough savings to garner a reconciliation payment.鈥�</p> Mon, 10 Jun 2024 15:33:24 -0500 Bundled Payment <div class="container"><div class="row"><div class="col-md-8"><p>The Centers for Medicare & Medicaid Innovation (CMMI) April 10 <a href="https://public-inspection.federalregister.gov/2024-07567.pdf">proposed</a> a new mandatory payment model 鈥� Transforming Episode Accountability Model (TEAM) 鈥� that would bundle payment to acute care hospitals for five types of surgical episodes. The proposed payment model, included as part of the fiscal year 2025 inpatient and long-term care hospital prospective payment system proposed rule, expands upon previous episode-based payment models like the Comprehensive Care for Joint Replacement and the Bundled Payments for Care Improvement Advanced models.</p><p><strong>The AHA has developed a model comment letter that hospitals and health systems can use to assist with submitting to CMS their own comments on the proposed rule. Click </strong><a href="/system/files/media/file/2024/06/Model-Comment-Letter-on-CMS-Transforming-Episode%20Accountability-Model-TEAM-Proposed-Rule.docx"><strong>here</strong></a><strong> to download the model letter.</strong> The letter includes language that urges CMS to not require mandatory participation in TEAM, to lower the proposed discount factor and pursue significant model design changes or not implement the model at all.</p><p>We strongly encourage members to submit their own comments and use the model letter as a guide to share your perspectives. Patient examples, data and other on-the-ground insights your organization can provide about your experience working with bundled payment models, and the impact this mandatory model would have on your patients and hospital will be important as CMS develops final regulations.</p><p>All comments must be submitted before <strong>5 p.m. ET June 10.</strong> You may submit electronic comments at <a href="https://www.regulations.gov">https://www.regulations.gov</a> by following the instructions under the 鈥渟ubmit a comment鈥� tab. Please refer to file code 鈥淐MS-1808-P鈥� when you submit your letter.</p><p>The AHA will submit its own detailed comment letter, which will be shared with hospitals and health systems once finalized.</p><p><strong>FURTHER QUESTIONS</strong></p><p>If you have further questions, please contact Jennifer Holloman, AHA鈥檚 senior director of policy for physician and alternative payment models, at <a href="mailto:jholloman@aha.org">jholloman@aha.org</a>. </p></div><div class="col-md-4"><a href="/system/files/media/file/2024/06/use-model-letter-to-submit-comments-on-cms-team-proposed-rule-alert-6-4-24.pdf" target="_blank"><img src="/sites/default/files/2024-06/cover-use-model-letter-to-submit-comments-on-cms%E2%80%99-team-proposed-rule-alert-6-4-24.png" data-entity-uuid data-entity-type="file" alt=" Cover Action Alert: Use Model Letter to Submit Comments on CMS鈥� TEAM Proposed Rule" width="NaN" height="NaN"></a></div></div></div> Tue, 04 Jun 2024 14:53:57 -0500 Bundled Payment /lettercomment/2024-05-17-aha-fah-request-comment-period-extension-proposed-mandatory-bundled-payment-model <p>May 17, 2024<br> </p><p>The Honorable Chiquita Brooks-LaSure<br>Administrator<br>Centers for Medicare & Medicaid Services<br>Hubert H. Humphrey Building<br>200 Independence Avenue, S.W., Room 445-G<br>Washington, DC 20201</p><p><em><strong>Re: CMS鈥�1808鈥揚: Medicare and Medicaid Programs and the Children鈥檚 Health Insurance Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2025 Rates; Quality Programs Requirements; and Other Policy Changes Proposed Rule (Vol. 89, No. 86), May 2, 2024.</strong></em></p><p>Dear Administrator Brooks-LaSure:</p><p>The 黑料正能量 Association (AHA) represents 5,000 member hospitals, health systems and other health care organizations, our clinician partners 鈥� including more than 270,000 affiliated physicians, 2 million nurses and other caregivers 鈥� and 43,000 health care leaders who belong to our professional membership groups. The Federation of 黑料正能量s (FAH) is the national representative of more than 1,000 leading tax-paying hospitals and health systems throughout the United States. Together, our members provide patients and communities with access to high-quality, affordable care. The AHA and FAH appreciate the opportunity to comment on the Transforming Episode Accountability Model (TEAM) proposals in the Centers for Medicare & Medicaid Services鈥� (CMS) inpatient prospective payment system (PPS) proposed rule for fiscal year (FY) 2025.</p><p>The AHA and FAH are both working closely with our hospital and health system members to assess the impact of the proposed rule on the critically important work they do in caring for their patients and communities. We are committed to providing thoughtful consideration of TEAM, but the scope of the rule is extremely broad. For example, the five types of surgical procedures proposed for inclusion in TEAM comprised over 11% of inpatient PPS payments in FY 2023 鈥� a staggering amount that doesn鈥檛 even include the outpatient payments that would be part of the model. In addition, based on initial feedback, we are concerned that CMS is not providing hospitals with the necessary tools to be successful under the program or appropriately balancing the risk versus reward equation. Additional time beyond 60 days is necessary to fully evaluate and analyze these proposed policies and their full impact across the health care spectrum. This is particularly true given that the agency proposed another hospital-based mandatory payment model just four weeks after it proposed TEAM. </p><p><strong>Therefore, we respectfully request that CMS extend the June 10 deadline for commenting on the rule鈥檚 TEAM proposals by at least an additional 30 days to July 10. We further ask that such an extension be issued as soon as possible to be of the most use to interested stakeholders. </strong>Doing so would help us ensure we are able to give the model the most thoughtful consideration and thereby most effectively move the health care system toward the provision of more accountable, coordinated care.</p><p>We appreciate your consideration of this request. Please contact us if you have questions or feel free to have a member of your team contact Jennifer Holloman, AHA鈥檚 senior associate director for policy, at <a href="mailto:jholloman@aha.org">jholloman@aha.org</a> or Don May, FAH鈥檚 senior vice president for policy, at <a href="mailto:dmay@fah.org">dmay@fah.org</a>.</p><p>Sincerely,</p><table><tbody><tr><td>/s/      <br><br>Stacey Hughes<br>Executive Vice President<br>Executive Vice President</td><td>/s/<br><br>Charlene MacDonald<br>Executive Vice President<br>Federation of 黑料正能量s</td></tr></tbody></table> Fri, 17 May 2024 13:51:18 -0500 Bundled Payment <p>The Center for Medicare & Medicaid Innovation (CMMI) on April 10th proposed a new mandatory bundled payment model called the Transforming Episode Accountability Model (TEAM). The proposed payment model, included as part of the <a href="/news/news/2024-04-10-cms-issues-hospital-ipps-proposed-rule-fy-2025" target="_blank">CY2025 Inpatient Prospective Payment System (IPPS) proposed rule</a>, expands upon previous episode-based payment models like the Comprehensive Care for Joint Replacement (CJR) model and the Bundled Payments for Care Improvement Advanced (BPCI-A) model. </p><p>On May 7, 2024, the AHA policy experts discussed the Transforming Episode Accountability Model (TEAM) in a webinar. Members can <a href="https://aha-org.zoom.us/rec/share/mp8VkV31Gw8obAVi3gu1mm1UTqYPYe8hchKvhHR2RXFt7yCHDvYceJE3hci65QYe.n0nu8qfOXFX8HfLW" target="_blank">View Recording</a><a href="https://zoom.us/rec/play/Zs0JYYDvxMYB26eZiU7lu3YJXxC9Mq1S-m7dRqIQInfGGYqmGeZXJ8US2EergbTyOg-KbpKNZ889TxuE.KmXemA8BTZtCBpYQ?autoplay=true" target="_blank"> </a>and <a href="/system/files/media/file/2024/05/TEAM%20Model%20Member%20Webinar%20Slides.pdf" download="file" target="_blank" title="Slides ">Download Slides</a> from the event. </p> Wed, 08 May 2024 10:43:39 -0500 Bundled Payment /news/headline/2023-02-21-cms-accepting-applications-extended-bundled-payment-model <p>Acute care hospitals, physician group practices and Medicare accountable care organizations may apply through May 31 to participate in the Bundled Payments for Care Improvement Advanced Model for two years beginning in January, the Centers for Medicare & Medicaid Services <a href="https://innovation.cms.gov/innovation-models/bpci-advanced/applicant-resources">announced</a> today. CMS launched the alternative payment model in 2018 to test whether bundling Medicare payments for certain inpatient and outpatient care reduces spending and improves quality, and last year <a href="/news/headline/2022-10-14-cms-extend-bundled-payment-model-through-2025">announced</a> plans to extend it through 2025. The extension will adjust the payment methodology in an effort to balance Medicare savings with incentives for model participation; require new convener participants to be Medicare providers, suppliers or ACOs; and provide additional technical assistance. Current participants can simply sign an amended participation agreement to continue to participate in the two-year extension. <br />  <br /> For more information, see the <a href="https://innovation.cms.gov/media/document/bpcia-model-overview-fact-sheet-my6">CMS fact sheet</a> and register to attend a March 9 webinar on the CMS <a href="https://deloitte.zoom.us/webinar/register/WN_NXLqpqjYTmaMw0Y-Vv2n-Q">request for applications</a>.</p> Tue, 21 Feb 2023 14:41:09 -0600 Bundled Payment /news/headline/2022-10-14-cms-extend-bundled-payment-model-through-2025 <p>The Centers for Medicare & Medicaid Services will extend through 2025 the<a href="https://innovation.cms.gov/innovation-models/bpci-advanced"> Bundled Payments for Care Improvement Advanced model</a>, which was set to expire this year. CMS launched the alternative payment model in 2018 to test whether bundling Medicare payments for certain inpatient and outpatient care reduces spending and improves quality. The agency expects early next year to request applications from Medicare providers, suppliers and accountable care organizations to participate in the two-year extension, which will include changes to the pricing methodology. <br />  </p> Fri, 14 Oct 2022 16:02:00 -0500 Bundled Payment /news/headline/2021-04-30-cms-finalizes-changes-hip-and-knee-bundled-payment-program <p>The Centers for Medicare & Medicaid Services April 29 issued a <a href="https://public-inspection.federalregister.gov/2021-09097.pdf">rule</a> finalizing changes to the Comprehensive Care for Joint Replacement model, which bundles payment to acute care hospitals for hip and knee replacement surgery. Under this model, hospitals in which a joint replacement has taken place are held financially accountable for episode quality and costs. <br />  <br /> Among other policies, CMS will extend the CJR model for an additional three years, through Dec. 31, 2024, beyond its current timeline. However, this extension will apply only to hospitals in the 34 metropolitan statistical areas in which participation was mandatory. Hospitals participating in the 鈥渧oluntary鈥� MSAs, as well as all low-volume and rural hospitals that have elected to participate, will continue to see the model end on Sept. 31, 2021.<br />  </p> Fri, 30 Apr 2021 14:39:24 -0500 Bundled Payment /special-bulletin/2021-04-30-cms-finalizes-changes-hip-and-knee-bundled-payment-program <div class="container"> <div class="row"> <div class="col-md-8"> <p>The Centers for Medicare & Medicaid Services (CMS) April 29 issued a <a href="https://public-inspection.federalregister.gov/2021-09097.pdf" target="_blank">rule finalizing changes to the Comprehensive Care for Joint Replacement (CJR) model</a>, which bundles payment to acute care hospitals for hip and knee replacement surgery. Under this model, hospitals in which a joint replacement has taken place are held financially accountable for episode quality and costs.</p> <p>Among other policies, CMS will extend the CJR model for an additional three years, through Dec. 31, 2024, beyond its current timeline. However, this extension will apply only to hospitals in the 34 metropolitan statistical areas (MSAs) in which participation was mandatory. Hospitals participating in the 鈥渧oluntary鈥� MSAs, as well as all low-volume and rural hospitals that have elected to participate, will continue to see the model end on Sept. 31, 2021.</p> <h2>AHA Take</h2> <p><strong>The AHA has long been supportive of voluntary participation in alternative payment models as a pathway to potentially improve care coordination and efficiency. As such, we are disappointed that CMS is not extending voluntary participation options in the CJR model, as we had advocated.</strong></p> <p>A summary with highlights of the final rule follows.</p> <h2>Highlights of the Final Rule</h2> <h3>Extension of Model</h3> <p>The CJR model had originally been scheduled to end after five years, on Dec. 31, 2020. Due to the COVID-19 public health emergency, CMS extended the last year of the model (performance year (PY) 5) through Sept. 31, 2021. It is now extending the model again, through Dec. 31, 2024. However, this extension will apply only to hospitals in the 34 metropolitan statistical areas (MSAs) in which participation was mandatory. Hospitals participating in the 鈥渧oluntary鈥� MSAs, as well as all low-volume and rural hospitals that have elected to participate, will continue to see the model end on Sept. 31, 2021. The additional PYs will be:</p> <ul> <li>PY 6: Oct. 1, 2021 through Dec. 31, 2022;</li> <li>PY 7: Jan. 1, 2023 through Dec. 31, 2023; and</li> <li>PY 8: Jan. 1, 2024 through Dec. 31, 2024.</li> </ul> <h3>Episode of Care</h3> <p>Currently, a CJR episode begins with a beneficiary鈥檚 admission to an inpatient prospective payment system hospital for a procedure assigned to either Medicare-severity diagnosis-related group (MS-DRG) 469 or 470.<sup><a href="#fn1">1</a></sup> However, CMS finalized its proposal to change this definition to address the fact that total knee arthroplasty (TKA) and total hip arthroplasty (THA) procedures have been removed from the inpatient-only list and are now being performed in both outpatient and inpatient settings. Specifically, CMS will include outpatient TKAs and THAs as episode 鈥渢riggers鈥� for CJR.</p> <h3>Payment Methodology</h3> <p>CMS currently uses three years of historical data to calculate hospital target prices. It set this policy because it was concerned that using less data would not generate stable target prices. However, as of PY 4 of the program, target prices are based entirely on historical data across an entire region, rather than across individual hospitals, which has mitigated CMS鈥� concerns about low volume. Thus, it will use one year of data to set target prices. Due to the COVID-19 public health emergency, CMS will not use fiscal year (FY) 2020 data to set target prices. It will use FY 2019 data to set target prices for PY 6, FY 2021 data to set target prices for PY 7, and FY 2022 data to set target prices for PY 8.</p> <p>In addition, as a means of risk adjustment for the model, CMS currently sets four separate target prices for each hospital: for MS-DRGs 469 and 470, for patients with and without hip fractures. However, the agency states that given its inclusion of outpatient THA and TKA procedures in the model, it believes additional risk adjustment is warranted. Thus, it finalized its proposal to also incorporate data on CMS hierarchical condition category (HCC) condition count and beneficiary age into the target price calculation. In addition, it also will incorporate dual-eligibility status into the target price calculation. CMS will use five CMS-HCC condition count variables to account for the expected marginal cost of treating beneficiaries with zero, one, two, three or four or more CMS-HCCs. It will use four age categories: less than 65, 65 to 74, 75 to 84 and 85 or more.</p> <p>In order to determine any shared savings, CMS currently compares a hospital鈥檚 actual spending to its target price minus a percent discount that varies depending on its quality score. Hospitals keep any savings they achieve in excess of this percent discount, again subject to quality performance. For the extension of the model (PYs 6 through 8), CMS finalized as proposed its changes to the discount amounts, which would provide more favorable factors for higher quality scores (see Table 1 below).</p> <table> <caption> <h3>Table 1: Discount Factor by Performance Year</h3> </caption> <tbody> <tr> <th>Quality Score</th> <th>Year 5</th> <th>Years 6-8</th> </tr> <tr> <td>Below acceptable</td> <td>N/A</td> <td>N/A</td> </tr> <tr> <td>Acceptable</td> <td>3.0%</td> <td>3.0%</td> </tr> <tr> <td>Good</td> <td>2.0%</td> <td>1.5%</td> </tr> <tr> <td>Excellent</td> <td>1.5%</td> <td>0.0%</td> </tr> </tbody> </table> <h3>Reconciliation</h3> <p>CMS finalized its proposed change to the high-episode spending cap used at reconciliation. Specifically, the agency implemented a high-episode spending cap policy to prevent hospitals from being held responsible for catastrophic episode spending that they could not have reasonably been expected to prevent. Under this policy, CMS caps the spending amount of episodes at two standard deviations above the mean. However, CMS is changing the methodology to cap episode spending at the 99th percentile. The agency believes this will more accurately represent the cost of infrequent and potentially non-preventable complications.</p> <p>CMS also finalized its proposal to move from two reconciliation periods (conducted two and 14 months after the close of each performance year) to one reconciliation period conducted six months after the close of each performance year. The agency has determined that the full 14 months is not necessarily required to sufficiently capture claims run out and overlap with other models. Rather, CMS believes that six months is adequate for capturing episode costs, and that one less reconciliation will reduce administrative burden for the agency and hospitals alike.</p> <h3>Quality Measurement</h3> <p>CMS retains the same quality measures for the extension of the model. The two mandatory quality measures are the hip/knee complications and Hospital Consumer Assessment of Providers and Systems measures that hospitals already report for the inpatient quality reporting program. In addition, CMS retains an optional patient-reported outcome (PRO) measure that enables hospitals to increase their composite quality score. However, CMS finalizes three modifications to its proposed PRO measure policies. First, it will adopt less aggressive increases to the data completeness thresholds. Instead of requiring that hospitals report on 100% of eligible cases by the final year of the extension, hospitals would now be required to report on 90% of cases. Second, CMS will extend the post-operative data collection window to 14 months to allow hospitals more time to collect data. Lastly, as a result of the extension of PY 5 of the model, CMS will shift the PY 6 pre-operative PRO data collection window by one year, to April 1, 2021 through June 30, 2022. The other performance periods and reporting deadlines will remain roughly consistent with prior years.</p> <h2>Next Steps</h2> <p>The final rule will be published in the May 3 Federal Register. AHA staff will continue to review and analyze it.</p> <p>If you have further questions, contact Joanna Hiatt Kim, AHA vice president of payment policy, at <a href="mailto:jkim@aha.org?subject=Question about Hip and Knee Bundled Payment Program">jkim@aha.org</a>.</p> <hr /> <ol> <li id="fn1">MS-DRG 469 is Major Joint Replacement or Reattachment of Lower Extremity with Major Complications or Comorbidities (MCC) and MS-DRG 470 is Major Joint Replacement or Reattachment of Lower.</li> </ol> </div> <div class="col-md-4"> <div> <h3>Key Takeaways</h3> <ul> <li>CMS will extend the CJR model for an additional three years, through Dec. 31, 2024.</li> <li>This extension will apply only to hospitals participating on a mandatory basis.</li> <li>CMS will add outpatient procedures to the CJR model, and, as a result, add additional risk adjustment as well.</li> <li>The agency will provide more favorable shared savings thresholds for hospitals with higher quality scores.</li> <li>CMS will use one year of data to set hospital pricing targets as compared to the current three years of data.</li> <li>CMS will retain the same quality measures for the extension of the model.</li> </ul> </div> </div> </div> </div> table, th, td { border: 1px solid black; } table { margin-bottom: 20px; } th { background-color: #b1b3b340; } Fri, 30 Apr 2021 14:06:37 -0500 Bundled Payment /center/population-health-management Fri, 18 Dec 2020 16:53:58 -0600 Bundled Payment /center/population-health-management/bundled_payments/learning_series Tue, 17 Nov 2020 11:00:23 -0600 Bundled Payment