CMS Issues Interim Rule Delaying Key Value-based Reimbursement Programs

The new Administration is hitting the pause button on several Medicare payment reform initiatives, including bundled payment initiatives, according to an interim final rule (IFR) published this week in the Federal Register.

The IFR delays the expansion of the Comprehensive Care for Joint Replacement (CJR) Model as well as the implementation of cardiac bundled payment initiatives from July 1, 2017 to October 1, 2017. The rule also pushes back the effective date of the Cardiac Rehabilitation Incentive Payment Model from July 1 to October 1, according to the Federal Register. Additionally, it moves the effective dates of a final rule that outlines the implementation of CJR and other bundled payment initiatives, pushing it from March 21 to May 20—the final rule’s second delay since February.

The Centers for Medicare and Medicaid Services (CMS), which published the rule, also noted it’s seeking “comment on the appropriateness of this delay, as well as a further applicability date delay until January 1, 2018,” according to the rule.

“This additional three-month delay is necessary to allow time for additional review, to ensure that the agency has adequate time to undertake notice and comment rulemaking to modify the policy if modifications are warranted, and to ensure that in such a case participants have a clear understanding of the governing rules and are not required to take needless compliance steps,” the rule states.

The CJR model and cardiac rehab payment model have been closely watched by clinical documentation improvement (CDI) and coding professionals because provider success with these payment models hinges on quality documentation.

At AHIMA’s 2016 CDI Summit, speaker Cheryl Ericson, MS, RN, CCDS, CDIP, from DHG Healthcare, noted that under the Affordable Care Act, CMS endeavored to tie an increasingly higher percentage of reimbursement to quality improvement programs by 2018.

At the Summit, Ericson said that Medicare’s CJR, which requires providers to complete joint replacement procedures and the needed rehabilitation and after care within 90 days for a lump sum, is a sign of things to come, the Journal reported at the time. Ericson predicted that as a response, large organizations would dedicate whole CDI teams to making sure these encounters are well-documented to meet compliance.

As MedCity News notes, Health and Human Services Secretary Tom Price has in the past been opposed to mandatory participation in value-based care initiatives.

“I’m not surprised at all [by the new rule],” naviHealth COO Carter Paine told MedCity News. “From a timing perspective, with Secretary Price only holding his seat for a couple weeks and Seema Verma getting confirmed last week, the prudent thing for them is to dig into these issues. I’m not surprised they’re delaying it and going through the implications.”

Click here to read the full interim rule.

Mary Butler is the associate editor at The Journal of AHIMA.

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